Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
SAFTA preferential tariff treatment could not be denied solely because the six-digit tariff classification in the country-of-origin certificate differed from the re-determined classification. Where the goods' description and Bangladeshi origin were undisputed, the revised headings remained covered by the exemption, and no specified ground for denial was established, the applicable origin rules required verification and consultation before rejecting preference. Transaction value could not be enhanced merely using NIDB data for allegedly similar branded goods without evidence of counterfeit goods, invoice unreliability, comparable quality or other relevant textile characteristics. The preferential exemption and declared value were restored, with consequential duty, interest, penalty, confiscation, redemption fine and bank guarantee measures set aside or released.
SAFTA preferential tariff treatment could not be denied solely because the six-digit tariff classification in the country-of-origin certificate differed from the re-determined classification. Where the goods' description and Bangladeshi origin were undisputed, the revised headings remained covered by the exemption, and no specified ground for denial was established, the applicable origin rules required verification and consultation before rejecting preference. Transaction value could not be enhanced merely using NIDB data for allegedly similar branded goods without evidence of counterfeit goods, invoice unreliability, comparable quality or other relevant textile characteristics. The preferential exemption and declared value were restored, with consequential duty, interest, penalty, confiscation, redemption fine and bank guarantee measures set aside or released.
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