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 affirmed the assessment: the AO's computation of business income at 8% of turnover under section 44AD was sustained, with CIT(A)'s concurrence upheld as a correct finding. Separately, additions relating to acquisition of an immovable asset were also upheld because the assessee failed to discharge the initial onus to establish receipts from relatives-no satisfactory identity, PAN/return evidence, bank statements evidencing receipt/debit, confirmation, repayment records or proof of creditworthiness were furnished. Consequently, the unexplained investment was disallowed and the assessee's appeal was dismissed in its entirety.
ITAT affirmed the assessment: the AO's computation of business income at 8% of turnover under section 44AD was sustained, with CIT(A)'s concurrence upheld as a correct finding. Separately, additions relating to acquisition of an immovable asset were also upheld because the assessee failed to discharge the initial onus to establish receipts from relatives-no satisfactory identity, PAN/return evidence, bank statements evidencing receipt/debit, confirmation, repayment records or proof of creditworthiness were furnished. Consequently, the unexplained investment was disallowed and the assessee's appeal was dismissed in its entirety.
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