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...
Provisional release security for imported readymade garments not involving intellectual property rights concerns may be modified where the demanded security substantially exceeds duty calculated on the declared value and Revenue's enhanced valuation remains uncertain. The notes state that the fourfold value enhancement required scrutiny and, following the cited Tribunal approach, the bank guarantee condition was reduced. Release was directed on a provisional assessment basis after execution of a bond for the full amount stipulated by Revenue, while the reduced bank guarantee applied to the identified non-IPR-affected goods.
Provisional release security for imported readymade garments not involving intellectual property rights concerns may be modified where the demanded security substantially exceeds duty calculated on the declared value and Revenue's enhanced valuation remains uncertain. The notes state that the fourfold value enhancement required scrutiny and, following the cited Tribunal approach, the bank guarantee condition was reduced. Release was directed on a provisional assessment basis after execution of a bond for the full amount stipulated by Revenue, while the reduced bank guarantee applied to the identified non-IPR-affected goods.
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