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...
Related-party imports can justify rejection of declared transaction value where the importer and foreign supplier are owned or controlled by the same family and the relationship was not disclosed; the Tribunal treated this as sufficient reason to doubt the truth of the declared value under the valuation rules. Once transaction value is rejected, re-determination must follow the prescribed sequential valuation scheme, with a rule-by-rule basis identified for each item. The Tribunal sustained valuation only for specified goods where supplier invoices or contemporaneous imports supported the adjustment, but set aside Rule 8 valuations based on unsupported materials such as manufacturers' invoices, handwritten cost sheets, domestic sale prices, or arbitrary loading. Consequential confiscation, redemption fine, and personal penalties were quashed.
Related-party imports can justify rejection of declared transaction value where the importer and foreign supplier are owned or controlled by the same family and the relationship was not disclosed; the Tribunal treated this as sufficient reason to doubt the truth of the declared value under the valuation rules. Once transaction value is rejected, re-determination must follow the prescribed sequential valuation scheme, with a rule-by-rule basis identified for each item. The Tribunal sustained valuation only for specified goods where supplier invoices or contemporaneous imports supported the adjustment, but set aside Rule 8 valuations based on unsupported materials such as manufacturers' invoices, handwritten cost sheets, domestic sale prices, or arbitrary loading. Consequential confiscation, redemption fine, and personal penalties were quashed.
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