Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Valuation of Goods - Contemporaneous Imports of camera stabilizer devices - identical/similar items with the same model numbers at higher and different unit prices - The Supreme Court observed that a comparative table of the imported goods showed them to be identical or similar to earlier imports, except for being labeled as an "unpopular brand." The Court noted the appellant's admission of minor differences in hardware and software but affirmed the finding that the goods were essentially the same. As such, the Court upheld the decision to discard the declared transaction value and impose penalties.
Valuation of Goods - Contemporaneous Imports of camera stabilizer devices - identical/similar items with the same model numbers at higher and different unit prices - The Supreme Court observed that a comparative table of the imported goods showed them to be identical or similar to earlier imports, except for being labeled as an "unpopular brand." The Court noted the appellant's admission of minor differences in hardware and software but affirmed the finding that the goods were essentially the same. As such, the Court upheld the decision to discard the declared transaction value and impose penalties.
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