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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
