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...
Customs valuation challenges the use of an English-recorded statement as voluntary where the deponent did not understand the language, rendering that statement unreliable; electronic invoices recovered from the proprietor's laptop were inadmissible after retraction and lacked contemporaneity with imports; local resale invoices could not be disregarded without testing their probative value; re-determination of transaction value requires particulars, notice and consideration of commercial factors (quantity, model/grade, contractual terms, discounts, relationship); absent identification of identical goods or adequate particulars, valuation adjustments, differential duty, confiscation and penalties were unsustainable.
Customs valuation challenges the use of an English-recorded statement as voluntary where the deponent did not understand the language, rendering that statement unreliable; electronic invoices recovered from the proprietor's laptop were inadmissible after retraction and lacked contemporaneity with imports; local resale invoices could not be disregarded without testing their probative value; re-determination of transaction value requires particulars, notice and consideration of commercial factors (quantity, model/grade, contractual terms, discounts, relationship); absent identification of identical goods or adequate particulars, valuation adjustments, differential duty, confiscation and penalties were unsustainable.
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