Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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Valuation of imported goods - stamping foils - rejection of declared value - The tribunal found that the department's reliance on proforma invoices for A-grade goods was misplaced, given the appellant's importation of B and C-grade goods. The tribunal also recognized the appellant's submission of contemporaneous import data supporting their declared values. - The tribunal concurred with the appellant that there was no evidence of extra payment to the foreign supplier beyond the invoice values. - Tribunal held that the appellant's declared values were justified, and the initial inculpatory statement could not be relied upon due to the coercive circumstances under which it was obtained.
Valuation of imported goods - stamping foils - rejection of declared value - The tribunal found that the department's reliance on proforma invoices for A-grade goods was misplaced, given the appellant's importation of B and C-grade goods. The tribunal also recognized the appellant's submission of contemporaneous import data supporting their declared values. - The tribunal concurred with the appellant that there was no evidence of extra payment to the foreign supplier beyond the invoice values. - Tribunal held that the appellant's declared values were justified, and the initial inculpatory statement could not be relied upon due to the coercive circumstances under which it was obtained.
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