Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
The ITAT allowed the appeal of the assessee and directed the AO to grant credit for TDS, including amounts deducted on maturity of RBI bonds, after verifying claims under Rule 37BA(3)(ii) of the I.T. Rules, 1962. The tribunal noted the assessee had already offered interest on an accrual basis and paid corresponding tax for AYs 2018-19 to 2022-23, having claimed proportionate TDS credits from intermediary deductors. The AO is instructed to verify the TDS receipts, adjust the assessee's computation for AY 2023-24, determine the resultant tax liability or refund, and pass consequential orders in accordance with the tribunal's directions.
The ITAT allowed the appeal of the assessee and directed the AO to grant credit for TDS, including amounts deducted on maturity of RBI bonds, after verifying claims under Rule 37BA(3)(ii) of the I.T. Rules, 1962. The tribunal noted the assessee had already offered interest on an accrual basis and paid corresponding tax for AYs 2018-19 to 2022-23, having claimed proportionate TDS credits from intermediary deductors. The AO is instructed to verify the TDS receipts, adjust the assessee's computation for AY 2023-24, determine the resultant tax liability or refund, and pass consequential orders in accordance with the tribunal's directions.
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