Validity of Assessment Order Challenged: Commissioner (Appeal) Lacked Authority for Audit u/s 17(6) on Import Value Enhancement.

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....Validity of assessment order - order for auditing u/s 17(6) by the proper officer - enhancement of value of imported goods - Commissioner (Appeal) could not have directed such an audit in terms of sub section (6) because audit as contemplated is the internal function of the revenue, for purpose of safeguarding the revenue, in case where re-assessment has been done by way of speaking order or otherwise....