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...
Faceless assessment scheme does not absorb the statutory preliminary inquiry procedure for reopening; the scheme's plain language excludes that inquiry process, so a notice to reopen may validly be issued by the jurisdictional assessing officer where the requisite inquiry and order were made by that officer. Reading the faceless scheme to incorporate the preliminary inquiry would alter the scheme and render issuance by a faceless officer meaningless. Conflicting views from other High Courts were noted, but the conclusion here is that automated allocation may trigger notice issuance while reassessment proceedings may proceed facelessly; notices issued by jurisdictional officers after April 2022 are upheld as valid.
Faceless assessment scheme does not absorb the statutory preliminary inquiry procedure for reopening; the scheme's plain language excludes that inquiry process, so a notice to reopen may validly be issued by the jurisdictional assessing officer where the requisite inquiry and order were made by that officer. Reading the faceless scheme to incorporate the preliminary inquiry would alter the scheme and render issuance by a faceless officer meaningless. Conflicting views from other High Courts were noted, but the conclusion here is that automated allocation may trigger notice issuance while reassessment proceedings may proceed facelessly; notices issued by jurisdictional officers after April 2022 are upheld as valid.
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