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 allowed the assessee's claim for deduction under s.80P(2)(a)(i) in respect of interest income of Rs.12,05,115, directing that the AO grant the deduction (noting no justification to withhold the residual 10.86% where 89.14% was already admitted). The Tribunal observed that, pursuant to binding Supreme Court precedent, only profits and gains attributable to transactions with non-members are ineligible for s.80P relief; interest income remains allowable. The Tribunal remitted the matter on the contested gross profit addition from fertiliser/PDS sales, noting the AO failed to account for operating expenditures; it directed the AO to examine the assessee's expenditures, determine the net profit or loss from those activities, and then recompute the allowable s.80P deduction.
ITAT allowed the assessee's claim for deduction under s.80P(2)(a)(i) in respect of interest income of Rs.12,05,115, directing that the AO grant the deduction (noting no justification to withhold the residual 10.86% where 89.14% was already admitted). The Tribunal observed that, pursuant to binding Supreme Court precedent, only profits and gains attributable to transactions with non-members are ineligible for s.80P relief; interest income remains allowable. The Tribunal remitted the matter on the contested gross profit addition from fertiliser/PDS sales, noting the AO failed to account for operating expenditures; it directed the AO to examine the assessee's expenditures, determine the net profit or loss from those activities, and then recompute the allowable s.80P deduction.
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