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...
Rejection of declared transaction value for imported consumer goods was held unjustified where purported original invoices were unsigned Xerox copies that did not match product descriptions or quantities and where there was no corroborative payment or bank transfer evidence; reliance on recovered documents without matching quantities/descriptions or payment corroboration cannot displace declared CIF values, and the redetermination of assessable value based on such documents was unsustainable, resulting in the set aside of the enhancement and consequential demand.
Rejection of declared transaction value for imported consumer goods was held unjustified where purported original invoices were unsigned Xerox copies that did not match product descriptions or quantities and where there was no corroborative payment or bank transfer evidence; reliance on recovered documents without matching quantities/descriptions or payment corroboration cannot displace declared CIF values, and the redetermination of assessable value based on such documents was unsustainable, resulting in the set aside of the enhancement and consequential demand.
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