Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Validity of Re-determination of Value - Goods have already been cleared from the port of import after examination and enhancement of value - The Appellate Tribunal found that the Department erred in re-determining the value of the imported goods, especially considering that the assessment orders had already been finalized and not challenged. The Tribunal ruled that the Department lacked the authority to subject the same machines to another examination and assessment. - The Tribunal concurred with the appellants’ interpretation of Customs Valuation Rules, particularly regarding the inapplicability of the depreciation method and the impermissibility of re-enhancing value after import clearance.
Validity of Re-determination of Value - Goods have already been cleared from the port of import after examination and enhancement of value - The Appellate Tribunal found that the Department erred in re-determining the value of the imported goods, especially considering that the assessment orders had already been finalized and not challenged. The Tribunal ruled that the Department lacked the authority to subject the same machines to another examination and assessment. - The Tribunal concurred with the appellants’ interpretation of Customs Valuation Rules, particularly regarding the inapplicability of the depreciation method and the impermissibility of re-enhancing value after import clearance.
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