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...
Rejection of declared transaction value was sustained because the importer and overseas suppliers were owned or controlled by the same persons, creating reasonable doubt about the truth of the declared price under customs valuation rules. Once transaction value was rejected, valuation had to proceed strictly in sequence through the prescribed rules; the authority could not combine rules or apply Rule 8 on an unspecified basis. Arbitrary loading based on an average undervaluation percentage was impermissible. Redetermination survived only for consignments where an actual invoice established the true value and for undeclared goods supported by contemporaneous imports. Confiscation, redemption fine and penalties under multiple provisions were set aside.
Rejection of declared transaction value was sustained because the importer and overseas suppliers were owned or controlled by the same persons, creating reasonable doubt about the truth of the declared price under customs valuation rules. Once transaction value was rejected, valuation had to proceed strictly in sequence through the prescribed rules; the authority could not combine rules or apply Rule 8 on an unspecified basis. Arbitrary loading based on an average undervaluation percentage was impermissible. Redetermination survived only for consignments where an actual invoice established the true value and for undeclared goods supported by contemporaneous imports. Confiscation, redemption fine and penalties under multiple provisions were set aside.
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