Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Customs valuation rules require the proper officer, before rejecting a declared transaction value, to form reasonable and cogent grounds for doubt, seek necessary information, disclose those grounds when requested, and provide a hearing under Rule 12. An importer's written consent to reassessment may dispense with a speaking order under Section 17(5), but does not make the enhanced value the declared transaction value, waive mandatory valuation procedures, or prevent challenge to final assessment. Enhancement of imported scrap values solely on consent was therefore set aside and remanded for fresh reassessment after statutory compliance and observance of natural justice.
Customs valuation rules require the proper officer, before rejecting a declared transaction value, to form reasonable and cogent grounds for doubt, seek necessary information, disclose those grounds when requested, and provide a hearing under Rule 12. An importer's written consent to reassessment may dispense with a speaking order under Section 17(5), but does not make the enhanced value the declared transaction value, waive mandatory valuation procedures, or prevent challenge to final assessment. Enhancement of imported scrap values solely on consent was therefore set aside and remanded for fresh reassessment after statutory compliance and observance of natural justice.
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