Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Liability to pay customs duty for goods imported under Special Advance Authorization was remitted for fresh consideration because the impugned order was non-speaking and did not address the petitioners contention that customs duty was not payable in view of Special Advance Authorization and a Customs Notification dated 01.04.2023; the respondent is directed to afford a personal hearing, decide on merits in accordance with law within four weeks, and, if the petitioner succeeds, consider waiver of detention and demurrage charges in accordance with law.
Liability to pay customs duty for goods imported under Special Advance Authorization was remitted for fresh consideration because the impugned order was non-speaking and did not address the petitioners contention that customs duty was not payable in view of Special Advance Authorization and a Customs Notification dated 01.04.2023; the respondent is directed to afford a personal hearing, decide on merits in accordance with law within four weeks, and, if the petitioner succeeds, consider waiver of detention and demurrage charges in accordance with law.
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