Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Customs valuation dispute over imported melamine considers whether declared transaction value was inflated to evade anti dumping duty. Tribunal emphasises the transaction value principle (GATT) and requires actual negotiated price evidence rather than reliance on a published price bulletin; consequence: confirmation of ADD based solely on market journal prices and untested electronic or recorded statements is unsustainable. Tribunal also notes electronic evidence and recorded statements require tendering with opportunity for cross examination before an adjudicating authority; absence of corroborative, cogent evidence undermines findings of deliberate overvaluation for ADD evasion.
Customs valuation dispute over imported melamine considers whether declared transaction value was inflated to evade anti dumping duty. Tribunal emphasises the transaction value principle (GATT) and requires actual negotiated price evidence rather than reliance on a published price bulletin; consequence: confirmation of ADD based solely on market journal prices and untested electronic or recorded statements is unsustainable. Tribunal also notes electronic evidence and recorded statements require tendering with opportunity for cross examination before an adjudicating authority; absence of corroborative, cogent evidence undermines findings of deliberate overvaluation for ADD evasion.
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