Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Written acceptance of customs reassessment may dispense with a speaking order but does not waive the statutory right to appeal. Declared transaction value cannot be rejected without complying with the Customs Act and Customs Valuation Rules: the importer must receive written grounds for doubting the declared value, and any redetermination must follow the prescribed sequential valuation method. Payment of enhanced duty under protest and undisclosed comparable-import data do not establish unconditional acceptance of enhanced value. Orders-in-Appeal rejecting valuation challenges solely because of acceptance letters were set aside, with consequential relief according to law.
Written acceptance of customs reassessment may dispense with a speaking order but does not waive the statutory right to appeal. Declared transaction value cannot be rejected without complying with the Customs Act and Customs Valuation Rules: the importer must receive written grounds for doubting the declared value, and any redetermination must follow the prescribed sequential valuation method. Payment of enhanced duty under protest and undisclosed comparable-import data do not establish unconditional acceptance of enhanced value. Orders-in-Appeal rejecting valuation challenges solely because of acceptance letters were set aside, with consequential relief according to law.
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