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...
Misdeclaration of the transaction value - Import of Copper Cathodes - Acceptance of loaded value of the consignments earlier - The tribunal noted that apart from the discrepancy in dates between the invoice and bill of lading, the revenue authority provided no valid reason to reject the declared value. The appellant's explanation regarding the variation in price was considered normal trade practice and was not refuted with evidence or reasoning by the revenue authority. Therefore, the tribunal ruled that the declared value should be accepted. - The tribunal affirmed that past acceptance of loaded values did not bind the appellant to accept the re-assessed value in the current case.
Misdeclaration of the transaction value - Import of Copper Cathodes - Acceptance of loaded value of the consignments earlier - The tribunal noted that apart from the discrepancy in dates between the invoice and bill of lading, the revenue authority provided no valid reason to reject the declared value. The appellant's explanation regarding the variation in price was considered normal trade practice and was not refuted with evidence or reasoning by the revenue authority. Therefore, the tribunal ruled that the declared value should be accepted. - The tribunal affirmed that past acceptance of loaded values did not bind the appellant to accept the re-assessed value in the current case.
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