Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
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For exempt-income disallowance under Rule 8D, only investments that actually yielded exempt income were to be considered, and the matter was remitted for recomputation. Notional interest on business advances was deleted because there was no actual accrual or receipt and the advances were not shown to be lending transactions. In transfer pricing, foreign currency loans repayable in US dollars were to be benchmarked by reference to LIBOR, not the domestic lending rate, while TNMM for AE sales was upheld and excluded comparables were sustained. A separate adjustment on outstanding receivables was rejected where working-capital effects were already reflected. The section 14A amount was also not added to book profit under MAT.
For exempt-income disallowance under Rule 8D, only investments that actually yielded exempt income were to be considered, and the matter was remitted for recomputation. Notional interest on business advances was deleted because there was no actual accrual or receipt and the advances were not shown to be lending transactions. In transfer pricing, foreign currency loans repayable in US dollars were to be benchmarked by reference to LIBOR, not the domestic lending rate, while TNMM for AE sales was upheld and excluded comparables were sustained. A separate adjustment on outstanding receivables was rejected where working-capital effects were already reflected. The section 14A amount was also not added to book profit under MAT.
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