Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Transaction value remains the primary customs valuation basis and cannot be rejected solely because the declared price appears low. Rule 12 requires reasonable doubt supported by evidence; NIDB data alone was insufficient where the Department did not establish undervaluation, additional consideration, flow-back, or comparability of alleged contemporaneous imports by quantity, commercial level, manufacturer, branding, quality or specifications. The article notes that invalid value enhancement defeats the consequential differential duty and interest demand. Where confiscation rests entirely on the failed undervaluation allegation and no independent misdeclaration is evidenced, confiscation, redemption fine and penalty are also unsustainable.
Transaction value remains the primary customs valuation basis and cannot be rejected solely because the declared price appears low. Rule 12 requires reasonable doubt supported by evidence; NIDB data alone was insufficient where the Department did not establish undervaluation, additional consideration, flow-back, or comparability of alleged contemporaneous imports by quantity, commercial level, manufacturer, branding, quality or specifications. The article notes that invalid value enhancement defeats the consequential differential duty and interest demand. Where confiscation rests entirely on the failed undervaluation allegation and no independent misdeclaration is evidenced, confiscation, redemption fine and penalty are also unsustainable.
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