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...
Declared value could be rejected where the proper officer had reason to doubt its truth or accuracy, and a forged consent letter provided a valid basis for rejection; valuation was then correctly made under the sequential rules using the value of similar Heavy Melting Scrap, and the challenge to valuation failed. A separate summons relating to a different customs broker regulations enquiry was irrelevant because it did not affect the valuation and weighment findings in the impugned orders. A proprietary concern has no separate legal existence from its proprietor, so an independent penalty on the concern could not stand once penalty had been imposed on the proprietor; the separate writ filed in the concern's name was therefore not maintainable.
Declared value could be rejected where the proper officer had reason to doubt its truth or accuracy, and a forged consent letter provided a valid basis for rejection; valuation was then correctly made under the sequential rules using the value of similar Heavy Melting Scrap, and the challenge to valuation failed. A separate summons relating to a different customs broker regulations enquiry was irrelevant because it did not affect the valuation and weighment findings in the impugned orders. A proprietary concern has no separate legal existence from its proprietor, so an independent penalty on the concern could not stand once penalty had been imposed on the proprietor; the separate writ filed in the concern's name was therefore not maintainable.
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