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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price (ALP) of transactions at Rs. Nil, which was accepted by the Dispute Resolution Panel (DRP) and Assessing Officer (AO). The TPO was not satisfied that the assessee had received services for which payments were made, leading to the ALP being set at Rs. Nil. The assessee faced challenges in submitting evidence due to a short timeframe and the impact of Covid. Additional evidence was filed under Rule 29, acknowledged as critical. The ITAT admitted the evidence, directing the AO/TPO to re-examine the case. The ITAT also directed consideration of the Proviso to Section 92C(2) for Business Support Services, granting the benefit to the assessee. The appeal of the assessee was allowed.
The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price (ALP) of transactions at Rs. Nil, which was accepted by the Dispute Resolution Panel (DRP) and Assessing Officer (AO). The TPO was not satisfied that the assessee had received services for which payments were made, leading to the ALP being set at Rs. Nil. The assessee faced challenges in submitting evidence due to a short timeframe and the impact of Covid. Additional evidence was filed under Rule 29, acknowledged as critical. The ITAT admitted the evidence, directing the AO/TPO to re-examine the case. The ITAT also directed consideration of the Proviso to Section 92C(2) for Business Support Services, granting the benefit to the assessee. The appeal of the assessee was allowed.
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