Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
SC held that engineering and technical service charges paid to a local agent of a foreign supplier are includible in the assessable value of imported goods under Customs Valuation Rules. The services provided by the Indian agent were directly related to the sale and constituted a condition of sale, thus falling under Rule 9(1)(e). The charges were not post-importation activities but product support services integral to the import transaction. The lower authorities' interpretation was upheld, and the appeal was dismissed, affirming that such service charges must be included in the customs valuation calculation.
SC held that engineering and technical service charges paid to a local agent of a foreign supplier are includible in the assessable value of imported goods under Customs Valuation Rules. The services provided by the Indian agent were directly related to the sale and constituted a condition of sale, thus falling under Rule 9(1)(e). The charges were not post-importation activities but product support services integral to the import transaction. The lower authorities' interpretation was upheld, and the appeal was dismissed, affirming that such service charges must be included in the customs valuation calculation.
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