Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Preferential tariff treatment based on Certificates of Origin requires prescribed, time-bound verification of the specific certificates presented and communication of the grounds for doubt. Verification concerning different certificates, general information about a supplier, or assumptions about the goods' origin does not displace documentary certificates. Retracted statements require independent corroboration and appropriate examination and cross-examination before reliance; an admission is not invariably conclusive. On these principles, denial of the preferential duty exemption, consequential duty demand, confiscation, redemption fine and penalties could not be sustained where the specific Certificates of Origin were neither statutorily verified nor rebutted by reliable corroborative evidence.
Preferential tariff treatment based on Certificates of Origin requires prescribed, time-bound verification of the specific certificates presented and communication of the grounds for doubt. Verification concerning different certificates, general information about a supplier, or assumptions about the goods' origin does not displace documentary certificates. Retracted statements require independent corroboration and appropriate examination and cross-examination before reliance; an admission is not invariably conclusive. On these principles, denial of the preferential duty exemption, consequential duty demand, confiscation, redemption fine and penalties could not be sustained where the specific Certificates of Origin were neither statutorily verified nor rebutted by reliable corroborative evidence.
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