Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Declared customs transaction value may be rejected only on cogent evidence of extra consideration or reliable contemporaneous imports of comparable goods at higher prices. The notes state that unsupported statements, uncertified electronic records, and uniform loading without consignment-specific comparability do not establish undervaluation. Where final assessments were made and no fraud, collusion, wilful misstatement, or suppression with intent to evade duty is proved, the extended demand period is unavailable. If the valuation-based demand fails, consequential duty, confiscation, interest, and penalty cannot stand; seized currency lacking a proven nexus must be released, and investigation deposits must be refunded with applicable interest.
Declared customs transaction value may be rejected only on cogent evidence of extra consideration or reliable contemporaneous imports of comparable goods at higher prices. The notes state that unsupported statements, uncertified electronic records, and uniform loading without consignment-specific comparability do not establish undervaluation. Where final assessments were made and no fraud, collusion, wilful misstatement, or suppression with intent to evade duty is proved, the extended demand period is unavailable. If the valuation-based demand fails, consequential duty, confiscation, interest, and penalty cannot stand; seized currency lacking a proven nexus must be released, and investigation deposits must be refunded with applicable interest.
Note: It is a system-generated summary and is for quick reference only.