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Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The case involved valuation of imported goods for duty levy and denial of CVD exemption. The issue was whether to consider declared value or actual payment to High Seas Seller. Tribunal held that exchange rate on Bill of Entry date applies. Citing precedents, it confirmed exchange rate relevance. CVD exemption was granted as appellant used goods as fertilizers. Demand for differential duty was set aside. Appeal allowed.
The case involved valuation of imported goods for duty levy and denial of CVD exemption. The issue was whether to consider declared value or actual payment to High Seas Seller. Tribunal held that exchange rate on Bill of Entry date applies. Citing precedents, it confirmed exchange rate relevance. CVD exemption was granted as appellant used goods as fertilizers. Demand for differential duty was set aside. Appeal allowed.
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