Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
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Transfer-pricing treatment of corporate guarantees to wholly owned associated enterprises is discussed as requiring an arm's length commission of 0.5%, rather than a bank-guarantee rate of 1.90%. For outstanding foreign-currency receivables from associated enterprises, the relevant benchmark is the market rate for the transaction currency, identified as LIBOR plus 200 basis points rather than domestic lending or deposit rates. A normal interest-free credit period of 60 days is to be allowed before computing interest. The resulting adjustments are confined to the guarantee commission and recomputation of receivables interest on those parameters.
Transfer-pricing treatment of corporate guarantees to wholly owned associated enterprises is discussed as requiring an arm's length commission of 0.5%, rather than a bank-guarantee rate of 1.90%. For outstanding foreign-currency receivables from associated enterprises, the relevant benchmark is the market rate for the transaction currency, identified as LIBOR plus 200 basis points rather than domestic lending or deposit rates. A normal interest-free credit period of 60 days is to be allowed before computing interest. The resulting adjustments are confined to the guarantee commission and recomputation of receivables interest on those parameters.
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