Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Non-submission of country-of-origin certificate resulted in denial of concessional rate of Basic Customs Duty under ASEAN FTA Preferential Tariff Agreement for steaming (non-coking) coal in bulk. Alteration/correction in the certificate did not satisfy provisions of operational certification procedures. Denying substantial benefits for technical errors would be unjust. Revenue doubted authenticity of certificate due to correction and date discrepancy, but provided no concrete proof. Procedure to check doubts regarding certificate was not followed. Impugned order set aside, appeals allowed by Appellate Tribunal.
Non-submission of country-of-origin certificate resulted in denial of concessional rate of Basic Customs Duty under ASEAN FTA Preferential Tariff Agreement for steaming (non-coking) coal in bulk. Alteration/correction in the certificate did not satisfy provisions of operational certification procedures. Denying substantial benefits for technical errors would be unjust. Revenue doubted authenticity of certificate due to correction and date discrepancy, but provided no concrete proof. Procedure to check doubts regarding certificate was not followed. Impugned order set aside, appeals allowed by Appellate Tribunal.
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