Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Consideration of transaction value and sequential redetermination under CVR rules is central, with rejection of declared value under Rule 12 followed by rules 3-9 valuation steps; the piece emphasises shifting onus and distinct burdens of proof in valuation disputes and accepts electronic records and account statements where authenticity is undisputed. It notes provisional assessments prevent attraction of penal provisions and, despite upholding assessable values after investigation and non-traversal by the importer, recommends setting aside confiscation, fines and penalties while allowing consequential relief as per law.
Consideration of transaction value and sequential redetermination under CVR rules is central, with rejection of declared value under Rule 12 followed by rules 3-9 valuation steps; the piece emphasises shifting onus and distinct burdens of proof in valuation disputes and accepts electronic records and account statements where authenticity is undisputed. It notes provisional assessments prevent attraction of penal provisions and, despite upholding assessable values after investigation and non-traversal by the importer, recommends setting aside confiscation, fines and penalties while allowing consequential relief as per law.
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