Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Customs valuation was redetermined using the supplier's export declaration and accepted where the importer did not produce alternate purchase documentation; the Tribunal upheld the enhanced assessable value and differential duty. The record supported misdeclaration of goods, quantity and value, so confiscation of the imported goods was sustained. In mitigation, the redemption fine and one specified penalty were reduced while all other penalties were set aside. The summary addresses valuation, misdescription/misdeclaration, confiscation, and selective remission of fiscal penalties as the operative effects.
Customs valuation was redetermined using the supplier's export declaration and accepted where the importer did not produce alternate purchase documentation; the Tribunal upheld the enhanced assessable value and differential duty. The record supported misdeclaration of goods, quantity and value, so confiscation of the imported goods was sustained. In mitigation, the redemption fine and one specified penalty were reduced while all other penalties were set aside. The summary addresses valuation, misdescription/misdeclaration, confiscation, and selective remission of fiscal penalties as the operative effects.
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