Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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