Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Valuation - deduction of discounts - though the availability of the discounts was known at the time of clearance of the goods, these were quantified later but are to be deducted from transaction value. Thus, at the time of clearance of goods, since there is no quantification of demand, provisional assessment needs to be resorted to - he rejection of the request for provisional assessment was incorrect and unsustainable in law - AT
Valuation - deduction of discounts - though the availability of the discounts was known at the time of clearance of the goods, these were quantified later but are to be deducted from transaction value. Thus, at the time of clearance of goods, since there is no quantification of demand, provisional assessment needs to be resorted to - he rejection of the request for provisional assessment was incorrect and unsustainable in law - AT
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