Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Deliberate misclassification of optical network terminals as subscriber end equipment, coupled with an ineligible exemption claim, justified invocation of the extended limitation period for customs-duty recovery. Inconsistent tariff classifications for technically similar goods, continued use of the disputed classification after provisional reassessment, and equipment approval identifying the goods as GPON ONT supported an inference of intentional duty evasion. The importer's oral assertion that the classification issue had not previously been raised did not rebut those circumstances. The Tribunal upheld the customs-duty demand and dismissed the appeals.
Deliberate misclassification of optical network terminals as subscriber end equipment, coupled with an ineligible exemption claim, justified invocation of the extended limitation period for customs-duty recovery. Inconsistent tariff classifications for technically similar goods, continued use of the disputed classification after provisional reassessment, and equipment approval identifying the goods as GPON ONT supported an inference of intentional duty evasion. The importer's oral assertion that the classification issue had not previously been raised did not rebut those circumstances. The Tribunal upheld the customs-duty demand and dismissed the appeals.
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