Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The Tribunal held that the original adjudicating authority had erred in denying the opportunity of cross-examination to the respondent during the adjudication proceedings, thereby violating the principles of natural justice. Consequently, the matter was remanded back to the original authority to reconsider the case after allowing the cross-examination of the Director of M/s Auspicious Ornaments. The Tribunal found no error in the direction given by the first appellate authority for remanding the matter, and hence, the appeal filed by the revenue was dismissed.
The Tribunal held that the original adjudicating authority had erred in denying the opportunity of cross-examination to the respondent during the adjudication proceedings, thereby violating the principles of natural justice. Consequently, the matter was remanded back to the original authority to reconsider the case after allowing the cross-examination of the Director of M/s Auspicious Ornaments. The Tribunal found no error in the direction given by the first appellate authority for remanding the matter, and hence, the appeal filed by the revenue was dismissed.
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