Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
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