Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Composite cargo handling classification turned on the contract's essential character: arranging containers, loading, multi-modal movement, freight coordination and delivery assurance together formed an integrated cargo handling service, so transport was only incidental. Separate invoicing, use of contractors, and the earlier order in the appellant's own case did not alter classification, especially after the widened definition from 16.05.2008. The Tribunal also upheld the extended period and penalties because several service components were excluded from the taxable value, resulting in short-payment on the full gross value.
Composite cargo handling classification turned on the contract's essential character: arranging containers, loading, multi-modal movement, freight coordination and delivery assurance together formed an integrated cargo handling service, so transport was only incidental. Separate invoicing, use of contractors, and the earlier order in the appellant's own case did not alter classification, especially after the widened definition from 16.05.2008. The Tribunal also upheld the extended period and penalties because several service components were excluded from the taxable value, resulting in short-payment on the full gross value.
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