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    <description>Additional evidence was admitted because it was directly relevant to the nature and taxability of foreign remittances and to the overseas status and capacity of the remitters. The Tribunal treated the materials as going to the root of the controversy, noted that they were largely third-party documents, and found no indication that earlier non-filing was deliberate or mala fide. Applying the principle that procedural rules should not defeat substantial justice, it restored the matter to the DRP for fresh adjudication after considering the additional evidence and giving the assessee an adequate opportunity of hearing.</description>
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