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 appeal and set aside the penalty imposed under section 271F. The Tribunal accepted the assessee's plea that failure to file the return under section 139(1) for the relevant assessment year was due to reasonable cause within the meaning of section 273B, namely that the assessee was wholly occupied assisting a close family member through acute legal and emotional distress coinciding with the filing deadline. Noting the absence of appellate concurrence by the CIT(A.) on the point of reasonable cause and considering the facts, ITAT held the levy by the AO and confirmation by the CIT(A.) unjustified and deleted the penalty; Ground No.1 allowed.
ITAT allowed the appeal and set aside the penalty imposed under section 271F. The Tribunal accepted the assessee's plea that failure to file the return under section 139(1) for the relevant assessment year was due to reasonable cause within the meaning of section 273B, namely that the assessee was wholly occupied assisting a close family member through acute legal and emotional distress coinciding with the filing deadline. Noting the absence of appellate concurrence by the CIT(A.) on the point of reasonable cause and considering the facts, ITAT held the levy by the AO and confirmation by the CIT(A.) unjustified and deleted the penalty; Ground No.1 allowed.
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