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...
Demurrage paid separately by the buyer and seller for vessel waiting time, outside letter-of-credit payment for imported goods, is not part of the price actually paid or payable and is not includible in transaction value. A differential customs-duty demand cannot rely on a valuation provision absent from the show cause notice; reliance on such a ground exceeds the notice. Extended limitation requires evidence of a positive act of wilful suppression intended to evade duty, and oral allegations alone are insufficient. On these grounds, the differential-duty demand based on demurrage was unsustainable, and the notice for the specified Bills of Entry was time-barred.
Demurrage paid separately by the buyer and seller for vessel waiting time, outside letter-of-credit payment for imported goods, is not part of the price actually paid or payable and is not includible in transaction value. A differential customs-duty demand cannot rely on a valuation provision absent from the show cause notice; reliance on such a ground exceeds the notice. Extended limitation requires evidence of a positive act of wilful suppression intended to evade duty, and oral allegations alone are insufficient. On these grounds, the differential-duty demand based on demurrage was unsustainable, and the notice for the specified Bills of Entry was time-barred.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
