Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
The dominant issue was whether the appellate order under s.250 was vitiated for breach of natural justice due to denial of a requested personal hearing through video conferencing under the Faceless Appeal Scheme, 2021. Since the record showed that a specific request for such hearing was made via the National Faceless Appeal Centre but no hearing was granted, the order was treated as procedurally infirm. The appeal was restored to the first appellate authority for de novo adjudication after granting an opportunity of personal hearing in accordance with the Scheme, with liberty to make a fresh request under the relevant clause. - ITAT
The dominant issue was whether the appellate order under s.250 was vitiated for breach of natural justice due to denial of a requested personal hearing through video conferencing under the Faceless Appeal Scheme, 2021. Since the record showed that a specific request for such hearing was made via the National Faceless Appeal Centre but no hearing was granted, the order was treated as procedurally infirm. The appeal was restored to the first appellate authority for de novo adjudication after granting an opportunity of personal hearing in accordance with the Scheme, with liberty to make a fresh request under the relevant clause. - ITAT
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