Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Customs valuation of imported High Pressure Laminate Sheets could not be enhanced where the redetermination relied substantially on a retracted statement and invoices of alleged contemporaneous imports that were not shown to be comparable. The tribunal found no acceptable supporting evidence beyond the retracted statement, and the relied-upon invoice described different goods. In the absence of reliable material to reject the declared value, the enhancement was unsustainable and the impugned valuation order was set aside.
Customs valuation of imported High Pressure Laminate Sheets could not be enhanced where the redetermination relied substantially on a retracted statement and invoices of alleged contemporaneous imports that were not shown to be comparable. The tribunal found no acceptable supporting evidence beyond the retracted statement, and the relied-upon invoice described different goods. In the absence of reliable material to reject the declared value, the enhancement was unsustainable and the impugned valuation order was set aside.
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