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...
Importation of J3 Grade stainless steel is held permissible based on controlling precedents, and reliance on those decisions removes the novelty of the issue as res integra; applying that principle the submission finds that Customs' allegations do not sustain penalties or forfeiture/refund demands, which are set aside with consequential relief. The commentary records that appeals were allowed on this ground and that the matter was decided on merits in favour of the importer, removing regulatory impediment to imports of the specified grade.
Importation of J3 Grade stainless steel is held permissible based on controlling precedents, and reliance on those decisions removes the novelty of the issue as res integra; applying that principle the submission finds that Customs' allegations do not sustain penalties or forfeiture/refund demands, which are set aside with consequential relief. The commentary records that appeals were allowed on this ground and that the matter was decided on merits in favour of the importer, removing regulatory impediment to imports of the specified grade.
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