Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Validity of assessment proceedings under section 147 turned on omission to issue statutory notice under section 143(2). The tribunal applied precedent establishing that issuance of notice under section 143(2) is mandatory where the Assessing Officer considers it necessary to verify understatement of income or underpayment of tax, and failure to issue such notice is not a curable procedural irregularity; consequence: assessments completed under section 147 read with section 144 without the mandatory notice are vitiated and the assessment orders are null and void, resulting in decision against the revenue.
Validity of assessment proceedings under section 147 turned on omission to issue statutory notice under section 143(2). The tribunal applied precedent establishing that issuance of notice under section 143(2) is mandatory where the Assessing Officer considers it necessary to verify understatement of income or underpayment of tax, and failure to issue such notice is not a curable procedural irregularity; consequence: assessments completed under section 147 read with section 144 without the mandatory notice are vitiated and the assessment orders are null and void, resulting in decision against the revenue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
