Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Re-assessment of import valuation complied with the requirement for a speaking order, but the enhanced assessable value was not determined in accordance with the Customs Valuation framework. The authority relied on contemporaneous import data and a DRI price alert to discard declared transaction value without applying the sequential tests under the Customs Valuation Rules, including proper comparison of identical goods at the same commercial level and substantially the same quantity. Because those procedural and rule-based requirements were not examined, the confirmation of the enhanced demands was held unsustainable and the impugned order was set aside.
Re-assessment of import valuation complied with the requirement for a speaking order, but the enhanced assessable value was not determined in accordance with the Customs Valuation framework. The authority relied on contemporaneous import data and a DRI price alert to discard declared transaction value without applying the sequential tests under the Customs Valuation Rules, including proper comparison of identical goods at the same commercial level and substantially the same quantity. Because those procedural and rule-based requirements were not examined, the confirmation of the enhanced demands was held unsustainable and the impugned order was set aside.
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