Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
The ITAT affirmed the PCIT's exercise of revisional jurisdiction under section 263, dismissing all grounds urged by the assessee. The Tribunal held that challenges to the jurisdictional validity of the original assessment for lack of notice under section 143(2) were not admissible in a revision appeal and were untimely, leaving the assessee free to raise them in proceedings on the assessment. The claim that receipts arose from three distinct educational institutions attracting exemption under section 10(23C)(iiiad) failed for want of a return claim, non-compliance and absence of verifiable recognition for multiple entities. The AO's allowance of 85% expenditure without adequate verification was found erroneous and prejudicial, and the revision order setting aside the assessment was upheld.
The ITAT affirmed the PCIT's exercise of revisional jurisdiction under section 263, dismissing all grounds urged by the assessee. The Tribunal held that challenges to the jurisdictional validity of the original assessment for lack of notice under section 143(2) were not admissible in a revision appeal and were untimely, leaving the assessee free to raise them in proceedings on the assessment. The claim that receipts arose from three distinct educational institutions attracting exemption under section 10(23C)(iiiad) failed for want of a return claim, non-compliance and absence of verifiable recognition for multiple entities. The AO's allowance of 85% expenditure without adequate verification was found erroneous and prejudicial, and the revision order setting aside the assessment was upheld.
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