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...
Modular kitchen components imported in CKD/SKD condition are classifiable as furniture under Chapter 94 determined at the time and condition of importation, but that classification does not displace the statutory valuation regime: administrative DGOV furniture valuation guidelines cannot override Section 14 or the sequence of the Customs Valuation Rules. Rejection of transaction value and revaluation under Rule 12 and Rule 4 must use truly comparable goods at the same commercial level and substantially the same quantity; a mechanical per kilogram partitioning of invoice value failed the comparability requirement and lacked proof that the parties' relationship influenced price, so enhancement for 11 consignments was set aside while remaining declared values were accepted under Rule 3(3)(a).
Modular kitchen components imported in CKD/SKD condition are classifiable as furniture under Chapter 94 determined at the time and condition of importation, but that classification does not displace the statutory valuation regime: administrative DGOV furniture valuation guidelines cannot override Section 14 or the sequence of the Customs Valuation Rules. Rejection of transaction value and revaluation under Rule 12 and Rule 4 must use truly comparable goods at the same commercial level and substantially the same quantity; a mechanical per kilogram partitioning of invoice value failed the comparability requirement and lacked proof that the parties' relationship influenced price, so enhancement for 11 consignments was set aside while remaining declared values were accepted under Rule 3(3)(a).
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