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 HC held that notices and the order issued under the surrendered PAN were invalid where the petitioner had surrendered its earlier PAN and filed the return for AY 2019-20 under a newly allotted PAN; the formal notice under the old PAN was communicated to the respondent's office on 14.06.2019 but proceedings continued under the surrendered PAN. Consequently, the impugned order under section 148A(d) and the notice under section 148 were quashed and set aside as issued without jurisdiction. The respondent remains at liberty to initiate fresh proceedings by issuing a valid notice under the new PAN in accordance with law.
The HC held that notices and the order issued under the surrendered PAN were invalid where the petitioner had surrendered its earlier PAN and filed the return for AY 2019-20 under a newly allotted PAN; the formal notice under the old PAN was communicated to the respondent's office on 14.06.2019 but proceedings continued under the surrendered PAN. Consequently, the impugned order under section 148A(d) and the notice under section 148 were quashed and set aside as issued without jurisdiction. The respondent remains at liberty to initiate fresh proceedings by issuing a valid notice under the new PAN in accordance with law.
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