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...
Imported polyester fabrics were held classifiable under CTI 5903 20 90 as polyurethane laminated textile fabrics, based on CRCL reports showing PU lamination; classifications under CTI 5903 90 90 and CTI 6006 32 00 were incorrect. The Anti Dumping Notification charging duty on PU coated fabrics did not extend to PU laminated goods, so the anti dumping demand was unsustainable. Rejection of transaction value under Valuation Rule 12 and re determination under the sequential valuation provisions (Rules 3-9) was found improvident because no specification mismatch justified rejection. Penalty for short levy for collusion or wilful misstatement was quashed accordingly.
Imported polyester fabrics were held classifiable under CTI 5903 20 90 as polyurethane laminated textile fabrics, based on CRCL reports showing PU lamination; classifications under CTI 5903 90 90 and CTI 6006 32 00 were incorrect. The Anti Dumping Notification charging duty on PU coated fabrics did not extend to PU laminated goods, so the anti dumping demand was unsustainable. Rejection of transaction value under Valuation Rule 12 and re determination under the sequential valuation provisions (Rules 3-9) was found improvident because no specification mismatch justified rejection. Penalty for short levy for collusion or wilful misstatement was quashed accordingly.
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