Validity of assessment order challenged for reliance on undisclosed CBEC import data, remanded for fresh decision

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....Validity of assessment order under Section 143(3) read with Section 144B was challenged where the assessing authority based an addition under Section 69 solely on aggregate import figures received from CBEC without furnishing breakup or underlying import bills; the court held that reliance on undisclosed third-party data without providing particulars or opportunity to reconcile breached principles of natural justice, vitiating the addition and assessment; the court noted prior transfer pricing scrutiny found purchases at arms length and remanded the matter for reconsideration after disclosure of the material relied upon.....