Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
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Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
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