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...
A subordinate adjudicating authority must follow an earlier appellate decision in the same matter unless it has been set aside by a superior court; mere disagreement with the reasoning or reliance on additional materials does not justify departure, so the impugned order was set aside for breach of judicial discipline. The imported track assembly, brake/case sub-assembly, gear vertical adjuster and bar seat track lock were integral seat-mechanism components supplied to seat manufacturers and were therefore classifiable as parts of seats under CTI 9401 90 00, not as parts and accessories of motor vehicles under CTI 8708 99 00. The reclassification was held erroneous and the assessee's classification was upheld.
A subordinate adjudicating authority must follow an earlier appellate decision in the same matter unless it has been set aside by a superior court; mere disagreement with the reasoning or reliance on additional materials does not justify departure, so the impugned order was set aside for breach of judicial discipline. The imported track assembly, brake/case sub-assembly, gear vertical adjuster and bar seat track lock were integral seat-mechanism components supplied to seat manufacturers and were therefore classifiable as parts of seats under CTI 9401 90 00, not as parts and accessories of motor vehicles under CTI 8708 99 00. The reclassification was held erroneous and the assessee's classification was upheld.
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