Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
Related-party customs valuation is addressed through rejection of the declared transaction value where undisclosed funding discounts and dual invoicing created reasonable doubt. The notes state that value should then be redetermined sequentially using deductive-value principles, flexibly applied through residual valuation, with the local list price treated as deemed resale price where contemporaneous sales data is unavailable. Only normal, known and uniformly available discounts may be deducted; warranty costs are not post-import expenses, while customs duty, brokerage and fees are deductible. International freight and insurance cannot be added again. CLCP cannot replace declared MRP for additional-duty assessment. The discussion also confines interest and equivalent penalty to basic customs duty, while denying special additional duty exemption and sustaining extended limitation for nondisclosure.
Related-party customs valuation is addressed through rejection of the declared transaction value where undisclosed funding discounts and dual invoicing created reasonable doubt. The notes state that value should then be redetermined sequentially using deductive-value principles, flexibly applied through residual valuation, with the local list price treated as deemed resale price where contemporaneous sales data is unavailable. Only normal, known and uniformly available discounts may be deducted; warranty costs are not post-import expenses, while customs duty, brokerage and fees are deductible. International freight and insurance cannot be added again. CLCP cannot replace declared MRP for additional-duty assessment. The discussion also confines interest and equivalent penalty to basic customs duty, while denying special additional duty exemption and sustaining extended limitation for nondisclosure.
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