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...
Rectification of customs documentation for an inadvertent typographical error in unit price was held to merit reconsideration; the petitioners' claim that invoices and purchase orders contained bona fide mistakes should be examined under the statutory rectification framework and relevant standing orders. The High Court found no adequate reason in the impugned communication to reject the case and set aside that communication, remanding the matter to the Deputy Commissioner of Customs to reconsider cancellation of out-of-charges, recall and reassessment of bills of entry, and amendment of unit price after hearing the petitioners. A decision is directed to be taken expeditiously within six weeks.
Rectification of customs documentation for an inadvertent typographical error in unit price was held to merit reconsideration; the petitioners' claim that invoices and purchase orders contained bona fide mistakes should be examined under the statutory rectification framework and relevant standing orders. The High Court found no adequate reason in the impugned communication to reject the case and set aside that communication, remanding the matter to the Deputy Commissioner of Customs to reconsider cancellation of out-of-charges, recall and reassessment of bills of entry, and amendment of unit price after hearing the petitioners. A decision is directed to be taken expeditiously within six weeks.
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