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 affirmed the First Appellate Authority: the assessee's claim of exemption under sections 10(34) and 10(35) was held admissible; the cancellation of registration under section 12A for FY 2014-15 precluded claim under section 11, rendering the dividend and unit income exempt under 10(34)/10(35). Alleged contravention of sections 13(1)(d) and 13(2)(h) was rejected because the impugned investment constituted accretion of bonus shares and did not attract section 13(1)(d). Claims for deduction under section 80G/80GGA were remitted to the AO for verification and allowance to entities registered under section 80G(3)(a)(iiif) in accordance with section 80G(4).
The ITAT affirmed the First Appellate Authority: the assessee's claim of exemption under sections 10(34) and 10(35) was held admissible; the cancellation of registration under section 12A for FY 2014-15 precluded claim under section 11, rendering the dividend and unit income exempt under 10(34)/10(35). Alleged contravention of sections 13(1)(d) and 13(2)(h) was rejected because the impugned investment constituted accretion of bonus shares and did not attract section 13(1)(d). Claims for deduction under section 80G/80GGA were remitted to the AO for verification and allowance to entities registered under section 80G(3)(a)(iiif) in accordance with section 80G(4).
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