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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Valuation of imported goods - Inclusion of lump sum and periodical patent and technology know how fee paid - The Tribunal analyzed the provisions of Rule 10 (1) (c) of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007, and relevant case laws. It was concluded that the royalty and technical know-how fees were not a condition of the sale of the imported goods. Thus, these fees should not be included in the transaction value. The court emphasized the distinction between costs related to the import of goods and those pertaining to post-importation manufacturing activities.
Valuation of imported goods - Inclusion of lump sum and periodical patent and technology know how fee paid - The Tribunal analyzed the provisions of Rule 10 (1) (c) of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007, and relevant case laws. It was concluded that the royalty and technical know-how fees were not a condition of the sale of the imported goods. Thus, these fees should not be included in the transaction value. The court emphasized the distinction between costs related to the import of goods and those pertaining to post-importation manufacturing activities.
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