Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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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