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...
Royalty added to the transaction value of imported raw materials was held unsustainable where the same Technology Assistance Agreement had already been examined in the assessee's own case and the royalty was not shown to be a condition of sale of the imported goods. In the absence of any change in facts, documents, or law, the earlier valuation ruling was followed and the demand for differential customs duty could not be sustained. The consequential interest and penalty were also set aside, with relief allowed accordingly.
Royalty added to the transaction value of imported raw materials was held unsustainable where the same Technology Assistance Agreement had already been examined in the assessee's own case and the royalty was not shown to be a condition of sale of the imported goods. In the absence of any change in facts, documents, or law, the earlier valuation ruling was followed and the demand for differential customs duty could not be sustained. The consequential interest and penalty were also set aside, with relief allowed accordingly.
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