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...
Imported embroidery threads were re-valued on the basis of the full transaction value because supplementary invoices and admitted extra payments showed that part of the price had been kept outside the banking channel. The absence of comparable import data did not defeat the demand, since the undervaluation was supported by the appellants' own documents and admissions. The Tribunal sustained the differential customs duty after re-determining the assessable value under the valuation rules, and upheld penalties on both the importer and its Director because the same evidence established suppression and wilful misstatement.
Imported embroidery threads were re-valued on the basis of the full transaction value because supplementary invoices and admitted extra payments showed that part of the price had been kept outside the banking channel. The absence of comparable import data did not defeat the demand, since the undervaluation was supported by the appellants' own documents and admissions. The Tribunal sustained the differential customs duty after re-determining the assessable value under the valuation rules, and upheld penalties on both the importer and its Director because the same evidence established suppression and wilful misstatement.
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