Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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Customs valuation of CIF-imported fresh apples must begin with the declared transaction value, which may be rejected only on cogent evidence that it does not reflect the price actually paid or payable. The Department bears the burden of proving undisclosed additional consideration; an upstream FOB transaction, prepaid freight, Non-GMO certificates, and uncorroborated statements do not by themselves establish omitted freight, insurance, or a different CIF consideration. Disclosure of import documents and the CIF Incoterm precludes extended limitation absent deliberate collusion, wilful misstatement, or suppression intended to evade duty. Where valuation and extended limitation fail, enhancement, value-based confiscation, redemption fine, and related penalties cannot stand.
Customs valuation of CIF-imported fresh apples must begin with the declared transaction value, which may be rejected only on cogent evidence that it does not reflect the price actually paid or payable. The Department bears the burden of proving undisclosed additional consideration; an upstream FOB transaction, prepaid freight, Non-GMO certificates, and uncorroborated statements do not by themselves establish omitted freight, insurance, or a different CIF consideration. Disclosure of import documents and the CIF Incoterm precludes extended limitation absent deliberate collusion, wilful misstatement, or suppression intended to evade duty. Where valuation and extended limitation fail, enhancement, value-based confiscation, redemption fine, and related penalties cannot stand.
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