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...
Preferential customs duty benefit may remain available where revised or rectified Certificates of Origin are submitted within the prescribed period and the goods' origin and certificate authenticity are undisputed. The discussion states that origin rules permit replacement of erroneous certificates and retrospective issuance, and that procedural discrepancies should be read harmoniously with domestic verification requirements rather than extinguish substantive treaty benefits. It also notes that subsequent submission of a valid certificate can cure format-related defects, including under third-party invoicing arrangements, without altering origin, value or goods description. On the stated facts, denial of concessional duty was treated as unsustainable and the related duty demand, interest and penalties were set aside.
Preferential customs duty benefit may remain available where revised or rectified Certificates of Origin are submitted within the prescribed period and the goods' origin and certificate authenticity are undisputed. The discussion states that origin rules permit replacement of erroneous certificates and retrospective issuance, and that procedural discrepancies should be read harmoniously with domestic verification requirements rather than extinguish substantive treaty benefits. It also notes that subsequent submission of a valid certificate can cure format-related defects, including under third-party invoicing arrangements, without altering origin, value or goods description. On the stated facts, denial of concessional duty was treated as unsustainable and the related duty demand, interest and penalties were set aside.
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