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 challenges the use of an English-recorded statement as voluntary where the deponent did not understand the language, rendering that statement unreliable; electronic invoices recovered from the proprietor's laptop were inadmissible after retraction and lacked contemporaneity with imports; local resale invoices could not be disregarded without testing their probative value; re-determination of transaction value requires particulars, notice and consideration of commercial factors (quantity, model/grade, contractual terms, discounts, relationship); absent identification of identical goods or adequate particulars, valuation adjustments, differential duty, confiscation and penalties were unsustainable.
Customs valuation challenges the use of an English-recorded statement as voluntary where the deponent did not understand the language, rendering that statement unreliable; electronic invoices recovered from the proprietor's laptop were inadmissible after retraction and lacked contemporaneity with imports; local resale invoices could not be disregarded without testing their probative value; re-determination of transaction value requires particulars, notice and consideration of commercial factors (quantity, model/grade, contractual terms, discounts, relationship); absent identification of identical goods or adequate particulars, valuation adjustments, differential duty, confiscation and penalties were unsustainable.
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