Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Applicability of admissibility rules for investigation statements and electronic records in customs valuation is examined: statements recorded under interrogation provisions cannot be relied upon for rejecting declared transaction value where the certificate and procedural safeguards for electronic records were not complied with, and where statements were retracted; absence of a panchnama for email printouts and noncompliance with the certificate requirement for investigative statements rendered reliance on such material improper, making re-determination of value under valuation rules and consequent penalties unsustainable, resulting in setting aside the valuation rejection and penalty imposition.
Applicability of admissibility rules for investigation statements and electronic records in customs valuation is examined: statements recorded under interrogation provisions cannot be relied upon for rejecting declared transaction value where the certificate and procedural safeguards for electronic records were not complied with, and where statements were retracted; absence of a panchnama for email printouts and noncompliance with the certificate requirement for investigative statements rendered reliance on such material improper, making re-determination of value under valuation rules and consequent penalties unsustainable, resulting in setting aside the valuation rejection and penalty imposition.
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