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...
Cross-objections under section 129A(4) may challenge any part of an appealed order and are to be disposed of as an appeal; the article notes that the preliminary objection to their scope was overruled. It reports that declared import values could not be rejected without evidence that a related-party relationship influenced price, that proforma invoices reflected additional consideration, or that remittances exceeded declared values. Revised retail sale price demands were described as unsupported because relevant invoices were not supplied and no statutory post-import redetermination mechanism existed. A therapeutic transdermal patch was treated as a medicament rather than a skin-care product. The article further notes that redemption fine was unavailable where goods were unavailable and confiscation grounds failed.
Cross-objections under section 129A(4) may challenge any part of an appealed order and are to be disposed of as an appeal; the article notes that the preliminary objection to their scope was overruled. It reports that declared import values could not be rejected without evidence that a related-party relationship influenced price, that proforma invoices reflected additional consideration, or that remittances exceeded declared values. Revised retail sale price demands were described as unsupported because relevant invoices were not supplied and no statutory post-import redetermination mechanism existed. A therapeutic transdermal patch was treated as a medicament rather than a skin-care product. The article further notes that redemption fine was unavailable where goods were unavailable and confiscation grounds failed.
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