Commission expenditure linked to pharmaceutical marketing income qualifies as business deduction when recipient identity, genuineness and business pur...
Country of Origin Certificates and declared transaction value supported preferential customs exemption where authenticity and invoice prices remained ...
Related-party customs valuation requires objectively founded reasonable doubt before rejecting the declared transaction value. Non-disclosure of an exporter's Suggested List Price, without evidence that the discount was abnormal, artificial or relationship-driven, does not justify rejection where comparable export-country discounts and commercial normality are established. Any reassessment must follow the prescribed valuation methods sequentially; the residual method cannot use the exporter's domestic-market price. Royalty, technical assistance and know-how fees are includible only when they relate to imported goods and are payable as a condition of sale. Payments for Indian manufacturing technology, and discontinued notional management fees, are therefore excluded absent evidence of import-price adjustment.
Related-party customs valuation requires objectively founded reasonable doubt before rejecting the declared transaction value. Non-disclosure of an exporter's Suggested List Price, without evidence that the discount was abnormal, artificial or relationship-driven, does not justify rejection where comparable export-country discounts and commercial normality are established. Any reassessment must follow the prescribed valuation methods sequentially; the residual method cannot use the exporter's domestic-market price. Royalty, technical assistance and know-how fees are includible only when they relate to imported goods and are payable as a condition of sale. Payments for Indian manufacturing technology, and discontinued notional management fees, are therefore excluded absent evidence of import-price adjustment.
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