Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Customs valuation must consider contemporaneous import values and adopt the lowest comparable transaction value under Rule 5(3) of the Customs Valuation Rules, 2007. The notes state that reliance on a later-period import value, without addressing comparable imports close to the declared price or complying with remand directions, cannot support enhancement of declared value. They further explain that where the undervaluation finding and differential-duty demand fail, consequential confiscation, redemption fine and penalties, including penalties on co-noticee partners absent independent grounds, cannot be sustained.
Customs valuation must consider contemporaneous import values and adopt the lowest comparable transaction value under Rule 5(3) of the Customs Valuation Rules, 2007. The notes state that reliance on a later-period import value, without addressing comparable imports close to the declared price or complying with remand directions, cannot support enhancement of declared value. They further explain that where the undervaluation finding and differential-duty demand fail, consequential confiscation, redemption fine and penalties, including penalties on co-noticee partners absent independent grounds, cannot be sustained.
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