Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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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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