Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Supplementary show cause notices must remain within the original notice's scope, comply with limitation, and allow an adequate opportunity to respond; fresh grounds introduced through late corrigenda breach natural justice. Preferential customs exemption based on certificates of origin cannot be denied without reliable evidence of inauthenticity, particularly where certificates were verified at import and remain uncancelled. Reclassification of decorative stainless-steel wall panels and profiles requires Revenue to discharge its evidentiary burden through representative samples, technical evidence, and legally admissible statements. Transaction value cannot be rejected or enhanced without compliance with valuation procedures and evidence of additional consideration. Where misdeclaration and undervaluation fail, suppression with intent to evade duty and related penalties do not survive.
Supplementary show cause notices must remain within the original notice's scope, comply with limitation, and allow an adequate opportunity to respond; fresh grounds introduced through late corrigenda breach natural justice. Preferential customs exemption based on certificates of origin cannot be denied without reliable evidence of inauthenticity, particularly where certificates were verified at import and remain uncancelled. Reclassification of decorative stainless-steel wall panels and profiles requires Revenue to discharge its evidentiary burden through representative samples, technical evidence, and legally admissible statements. Transaction value cannot be rejected or enhanced without compliance with valuation procedures and evidence of additional consideration. Where misdeclaration and undervaluation fail, suppression with intent to evade duty and related penalties do not survive.
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