Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Tribunal held Adjudicating Authority's order cryptic, failing to examine appellants' defense regarding legitimate procurement and supply of gold as business transaction. Authority did not evaluate evidence u/s 108, authenticity of duty-paid invoices, or assayer's disclaimer on foreign origin. Passing common order without appreciating individual facts and evidence amounts to non-application of mind, violating principles of natural justice. Matter remanded to Original Authority for fresh adjudication as impugned order lacked reasoning, not a speaking order. Appeal allowed by way of remand to Adjudicating Authority.
Tribunal held Adjudicating Authority's order cryptic, failing to examine appellants' defense regarding legitimate procurement and supply of gold as business transaction. Authority did not evaluate evidence u/s 108, authenticity of duty-paid invoices, or assayer's disclaimer on foreign origin. Passing common order without appreciating individual facts and evidence amounts to non-application of mind, violating principles of natural justice. Matter remanded to Original Authority for fresh adjudication as impugned order lacked reasoning, not a speaking order. Appeal allowed by way of remand to Adjudicating Authority.
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