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...
Declared transaction value could not be rejected merely because the discount appeared abnormal, where the importer produced invoices, purchase orders and Cisco communications supporting the higher discount, and the Revenue's comparative material was not examined for comparability. The Tribunal noted there was no allegation of relationship between the importer and supplier or of any payment over and above invoice price. Because the evidentiary record on both sides had not been properly considered, the rejection of value was unsustainable. The order was set aside and the matter remanded for fresh examination of the documents and redetermination of assessable value.
Declared transaction value could not be rejected merely because the discount appeared abnormal, where the importer produced invoices, purchase orders and Cisco communications supporting the higher discount, and the Revenue's comparative material was not examined for comparability. The Tribunal noted there was no allegation of relationship between the importer and supplier or of any payment over and above invoice price. Because the evidentiary record on both sides had not been properly considered, the rejection of value was unsustainable. The order was set aside and the matter remanded for fresh examination of the documents and redetermination of assessable value.
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