Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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Statements of key witnesses could not be relied upon where cross-examination was not permitted, especially in light of the High Court's direction that such statements would be unusable without cross-examination. The Tribunal also noted that the certificates of origin issued by the overseas authorities remained valid and had not been cancelled, so the Revenue's allegation that they were improper was unsupported. Following its earlier decision on identical facts, the Tribunal found no infirmity in dropping the proceedings and dismissed the Revenue's appeals.
Statements of key witnesses could not be relied upon where cross-examination was not permitted, especially in light of the High Court's direction that such statements would be unusable without cross-examination. The Tribunal also noted that the certificates of origin issued by the overseas authorities remained valid and had not been cancelled, so the Revenue's allegation that they were improper was unsupported. Following its earlier decision on identical facts, the Tribunal found no infirmity in dropping the proceedings and dismissed the Revenue's appeals.
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