Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Related-party customs valuation was re-opened because later investigation disclosed fresh agreements, merger-related changes and different valuation methodologies, so earlier SVB and Tribunal orders did not bar reconsideration. The declared transaction value was rejected as not reflecting an uninfluenced price; valuation was directed on the deductive method where list price existed and on the computed method where it did not, with a 38% trade discount, admissible general expenses, and no separate addition for freight or insurance. Exemption under Notification No. 89/1982-Cus. was denied for SAD under strict construction, the extended limitation period was upheld for suppression, confiscation on an unnotified ground was set aside, and interest and penalty survived only for the BCD component.
Related-party customs valuation was re-opened because later investigation disclosed fresh agreements, merger-related changes and different valuation methodologies, so earlier SVB and Tribunal orders did not bar reconsideration. The declared transaction value was rejected as not reflecting an uninfluenced price; valuation was directed on the deductive method where list price existed and on the computed method where it did not, with a 38% trade discount, admissible general expenses, and no separate addition for freight or insurance. Exemption under Notification No. 89/1982-Cus. was denied for SAD under strict construction, the extended limitation period was upheld for suppression, confiscation on an unnotified ground was set aside, and interest and penalty survived only for the BCD component.
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