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 SC dismissed the SLP, upholding the HC's affirmance of the ITAT's factual conclusion that the AO's addition of alleged outstanding liabilities payable to two banks to the assessee's returned income was justified. The Court held the genuineness and existence of the claimed transactions were questions of fact, noting the absence of sufficient evidentiary material to demonstrate receipt (and subsequent return) of goods or to substantiate the asserted liabilities. No perversity or patent illegality in the concurrent findings of fact was found, and there was no basis to interfere with the impugned HC order sustaining the addition.
The SC dismissed the SLP, upholding the HC's affirmance of the ITAT's factual conclusion that the AO's addition of alleged outstanding liabilities payable to two banks to the assessee's returned income was justified. The Court held the genuineness and existence of the claimed transactions were questions of fact, noting the absence of sufficient evidentiary material to demonstrate receipt (and subsequent return) of goods or to substantiate the asserted liabilities. No perversity or patent illegality in the concurrent findings of fact was found, and there was no basis to interfere with the impugned HC order sustaining the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
