Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
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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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