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 digital projectors leased to cinema halls on a right-to-use basis were treated as goods not intended for retail sale, so RSP-based CVD valuation was not permissible because the package requirement for declaring retail sale price was absent. The note states that assessable value had to be determined on transaction value rather than RSP, and the enhancement on MRP basis was unsustainable. It also states that actual freight and actual insurance had to be adopted where those costs were available on record, making notional loading at 20% of FOB for freight and 1.125% of FOB for insurance unjustified. Consequential amendment of the Bills of Entry was allowed.
Imported digital projectors leased to cinema halls on a right-to-use basis were treated as goods not intended for retail sale, so RSP-based CVD valuation was not permissible because the package requirement for declaring retail sale price was absent. The note states that assessable value had to be determined on transaction value rather than RSP, and the enhancement on MRP basis was unsustainable. It also states that actual freight and actual insurance had to be adopted where those costs were available on record, making notional loading at 20% of FOB for freight and 1.125% of FOB for insurance unjustified. Consequential amendment of the Bills of Entry was allowed.
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