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 dismissed both appeals and affirmed the appellate order: the AO's addition under s.69B relating to the cost of cold storage structure was set aside because the CIT(A) properly accepted the DVO's revised valuation report after the DVO considered the assessee's objections, and the minor variation in the revised report did not warrant addition. The CIT(A)'s deletion of the impugned addition was endorsed. With respect to unexplained investment in plant and machinery, the CIT(A)'s decision to uphold the assessment was retained. Consequently, the assessee's appeals are dismissed and the Revenue's appeal is also dismissed.
ITAT dismissed both appeals and affirmed the appellate order: the AO's addition under s.69B relating to the cost of cold storage structure was set aside because the CIT(A) properly accepted the DVO's revised valuation report after the DVO considered the assessee's objections, and the minor variation in the revised report did not warrant addition. The CIT(A)'s deletion of the impugned addition was endorsed. With respect to unexplained investment in plant and machinery, the CIT(A)'s decision to uphold the assessment was retained. Consequently, the assessee's appeals are dismissed and the Revenue's appeal is also dismissed.
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