Person chargeable with duty must be the importer at importation; subsequent purchasers cannot be held liable where beneficial owner rules did not appl...
Prohibited importation of cosmetics without prior regulatory registration attracts seizure and confiscation; warehousing or re export claims do not cu...
Provisional release on security permitted where cash deposit plus bond secures differential duty; classification and treaty benefits referred for deci...
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
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