Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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