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 partly allowed the appeal in respect of additions under s.69A r.w.s. and s.115BBE arising from a search at common family premises. The AO's jewellery additions were deleted by the CIT(A) on factual analysis that the jewellery belonged to the family; Revenue did not challenge that finding, rendering it final. As to wrist watches, the AO had attributed all watches to the assessee, but CIT(A) found they were located in a shared residence occupied by multiple family members and, given the family's status and absence of purchase particulars, declined to uphold additions based on contemporary market valuation. The net result is deletion of jewellery additions and rejection of watch additions, with the appeal therefore partly allowed.
ITAT partly allowed the appeal in respect of additions under s.69A r.w.s. and s.115BBE arising from a search at common family premises. The AO's jewellery additions were deleted by the CIT(A) on factual analysis that the jewellery belonged to the family; Revenue did not challenge that finding, rendering it final. As to wrist watches, the AO had attributed all watches to the assessee, but CIT(A) found they were located in a shared residence occupied by multiple family members and, given the family's status and absence of purchase particulars, declined to uphold additions based on contemporary market valuation. The net result is deletion of jewellery additions and rejection of watch additions, with the appeal therefore partly allowed.
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