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...
Reopening of assessment was valid where specific information and documentary material, including affidavits and tally entries naming lenders, connected to the AOs independent formation of belief that income had escaped assessment, establishing a live link and satisfying the tangible material requirement for initiating proceedings; therefore reassessment jurisdiction was sustained. Separately, denial of opportunity to cross-examine a witness whose statement formed the basis of additions violated principles of natural justice; the impugned appellate order is set aside on that issue and the matter is remitted with direction to permit cross-examination.
Reopening of assessment was valid where specific information and documentary material, including affidavits and tally entries naming lenders, connected to the AOs independent formation of belief that income had escaped assessment, establishing a live link and satisfying the tangible material requirement for initiating proceedings; therefore reassessment jurisdiction was sustained. Separately, denial of opportunity to cross-examine a witness whose statement formed the basis of additions violated principles of natural justice; the impugned appellate order is set aside on that issue and the matter is remitted with direction to permit cross-examination.
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