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 held that foreign remittances characterized as "management/processing fees" are not taxable as fees for technical services (FTS) and therefore the addition treating them as FTS is deleted; the appeal ground challenging taxability is allowed following a co-ordinate bench precedent in the assessee's own case. With respect to levy of fee under s.234F, the Tribunal directed the AO to verify the assessee's contention that the return was filed in response to an s.148 notice and, if established, to take action in accordance with law regarding applicability of s.234F.
ITAT held that foreign remittances characterized as "management/processing fees" are not taxable as fees for technical services (FTS) and therefore the addition treating them as FTS is deleted; the appeal ground challenging taxability is allowed following a co-ordinate bench precedent in the assessee's own case. With respect to levy of fee under s.234F, the Tribunal directed the AO to verify the assessee's contention that the return was filed in response to an s.148 notice and, if established, to take action in accordance with law regarding applicability of s.234F.
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