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 - 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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