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...
ITAT quashed the reassessment orders for AYs 2013-14 and 2014-15, finding jurisdictional defects: the assessing authorities failed to supply the sanction under section 151 and the material relied upon in the reasons recorded under section 148(2), and the effective addition for AY 2014-15 (₹31,50,213) fell below the monetary threshold in section 149(1)(b), rendering reopening invalid. For AY 2018-19, the assessment was quashed because the order did not specify which deeming provisions (sections 68-69D) were invoked for alleged unaccounted income from accommodation entries, vitiating the assumption of jurisdiction. For AY 2021-22 the approval dated 28.06.2022 was held to be mechanically recorded ("Approved"), thus invalidating the sanction and the consequential assessment.
ITAT quashed the reassessment orders for AYs 2013-14 and 2014-15, finding jurisdictional defects: the assessing authorities failed to supply the sanction under section 151 and the material relied upon in the reasons recorded under section 148(2), and the effective addition for AY 2014-15 (₹31,50,213) fell below the monetary threshold in section 149(1)(b), rendering reopening invalid. For AY 2018-19, the assessment was quashed because the order did not specify which deeming provisions (sections 68-69D) were invoked for alleged unaccounted income from accommodation entries, vitiating the assumption of jurisdiction. For AY 2021-22 the approval dated 28.06.2022 was held to be mechanically recorded ("Approved"), thus invalidating the sanction and the consequential assessment.
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