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...
Residual customs penalty provisions apply only where a contravention, abetment, or statutory non-compliance is established and no separate penalty is prescribed. Penalty discretion must be exercised reasonably, rationally, and proportionately; it cannot justify a mechanical maximum penalty where a bona fide re-export request, unobjectionable goods, unavailable transport, and required no-objections reveal no identified breach. The penalty was therefore set aside. Detention and demurrage arising from Customs-attributable delay in permitting re-export cannot fairly be imposed on the importer or exporter after compliance with re-export conditions. A waiver certificate was directed for charges accruing until the let export order became available.
Residual customs penalty provisions apply only where a contravention, abetment, or statutory non-compliance is established and no separate penalty is prescribed. Penalty discretion must be exercised reasonably, rationally, and proportionately; it cannot justify a mechanical maximum penalty where a bona fide re-export request, unobjectionable goods, unavailable transport, and required no-objections reveal no identified breach. The penalty was therefore set aside. Detention and demurrage arising from Customs-attributable delay in permitting re-export cannot fairly be imposed on the importer or exporter after compliance with re-export conditions. A waiver certificate was directed for charges accruing until the let export order became available.
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