Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Related-party imports may justify reasonable doubt about declared transaction values under Rule 10A, supporting rejection of those values even without sufficient proof of cash payment of differential amounts. After rejection, customs valuation methods must be applied sequentially, ruling out each preceding method before using the next, with the applicable rule identified for each good and Bill of Entry. Recovered genuine invoices may support re-determination for specified goods, but residual valuation cannot rely on available contemporaneous imports or sales, impermissible domestic or foreign prices, or arbitrary average loading. Penalties under sections 112 and 114A are mutually exclusive and cannot be combined.
Related-party imports may justify reasonable doubt about declared transaction values under Rule 10A, supporting rejection of those values even without sufficient proof of cash payment of differential amounts. After rejection, customs valuation methods must be applied sequentially, ruling out each preceding method before using the next, with the applicable rule identified for each good and Bill of Entry. Recovered genuine invoices may support re-determination for specified goods, but residual valuation cannot rely on available contemporaneous imports or sales, impermissible domestic or foreign prices, or arbitrary average loading. Penalties under sections 112 and 114A are mutually exclusive and cannot be combined.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
