Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT set aside the impugned order of the CIT(A) and restored the matter to the file of the CIT(A) for de novo adjudication. The Tribunal noted that the joint development agreement was subsequently cancelled and no development was executed-facts central to whether a transfer occurred under section 2(24) read with the Transfer of Property Act-which the CIT(A) had overlooked. The CIT(A) is directed to afford the assessee an opportunity of hearing, to consider all documentary evidence tendered, and to decide the issue afresh by a reasoned, speaking order in accordance with law. Proceedings are remitted for reconsideration on these specified factual and legal aspects.
ITAT set aside the impugned order of the CIT(A) and restored the matter to the file of the CIT(A) for de novo adjudication. The Tribunal noted that the joint development agreement was subsequently cancelled and no development was executed-facts central to whether a transfer occurred under section 2(24) read with the Transfer of Property Act-which the CIT(A) had overlooked. The CIT(A) is directed to afford the assessee an opportunity of hearing, to consider all documentary evidence tendered, and to decide the issue afresh by a reasoned, speaking order in accordance with law. Proceedings are remitted for reconsideration on these specified factual and legal aspects.
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