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...
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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