TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Co-terminus appellate powers require full verification before deleting TDS disallowances for alleged non-deduction of tax on freight-forwarding paymen...
Customs valuation requires disclosure of the grounds for doubting the truth or accuracy of the declared transaction value, followed by sequential application of the valuation rules. NIDB data or routinely adopted rates cannot support value enhancement unless the relevant Bills of Entry, declared values, and comparability of goods by country of origin, commercial level and quantity are established. Enhancement founded solely on undisclosed routine rates is unsustainable. For alleged misdeclaration, examination differences that may be commercially addressed under a supply agreement do not establish fraud, suppression or wilful misstatement without supporting evidence. In those circumstances, confiscation, redemption fine and penalties are not justified.
Customs valuation requires disclosure of the grounds for doubting the truth or accuracy of the declared transaction value, followed by sequential application of the valuation rules. NIDB data or routinely adopted rates cannot support value enhancement unless the relevant Bills of Entry, declared values, and comparability of goods by country of origin, commercial level and quantity are established. Enhancement founded solely on undisclosed routine rates is unsustainable. For alleged misdeclaration, examination differences that may be commercially addressed under a supply agreement do not establish fraud, suppression or wilful misstatement without supporting evidence. In those circumstances, confiscation, redemption fine and penalties are not justified.
Note: It is a system-generated summary and is for quick reference only.