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Post-sale discounts and non-monetary benefits in a principal-to-principal supply dispute could not be examined on merits because the factual basis before the appellate authority had materially changed. The original advance ruling had proceeded on the supplier-franchise relationship and the absence of any prior agreement on such benefits, while the appeal introduced a different case based on principal-to-principal transactions and prior scheme documents. As the altered facts were divergent from those placed before the original authority, the AAAR held that the correctness of the earlier ruling could not be determined on that record and remanded the matter to the AAR for fresh consideration in accordance with natural justice.
Post-sale discounts and non-monetary benefits in a principal-to-principal supply dispute could not be examined on merits because the factual basis before the appellate authority had materially changed. The original advance ruling had proceeded on the supplier-franchise relationship and the absence of any prior agreement on such benefits, while the appeal introduced a different case based on principal-to-principal transactions and prior scheme documents. As the altered facts were divergent from those placed before the original authority, the AAAR held that the correctness of the earlier ruling could not be determined on that record and remanded the matter to the AAR for fresh consideration in accordance with natural justice.
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