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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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For customs valuation, the amended transaction-value regime requires acceptance of the price actually paid or payable in the particular import transaction where buyer and seller are unrelated and price is the sole consideration. Where the original consignee defaulted without payment, bill of entry, title, or delivery, its initial contract did not establish the relevant sale value. The subsequent importer's renegotiated price paid to the overseas supplier was treated as transaction value because no relationship, additional consideration, or excess payment was alleged. Earlier deemed-value rulings under the pre-amendment regime were inapplicable. The majority view sustained the declared value and dismissed Revenue's appeal.
For customs valuation, the amended transaction-value regime requires acceptance of the price actually paid or payable in the particular import transaction where buyer and seller are unrelated and price is the sole consideration. Where the original consignee defaulted without payment, bill of entry, title, or delivery, its initial contract did not establish the relevant sale value. The subsequent importer's renegotiated price paid to the overseas supplier was treated as transaction value because no relationship, additional consideration, or excess payment was alleged. Earlier deemed-value rulings under the pre-amendment regime were inapplicable. The majority view sustained the declared value and dismissed Revenue's appeal.
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