Person chargeable with duty must be the importer at importation; subsequent purchasers cannot be held liable where beneficial owner rules did not appl...
Prohibited importation of cosmetics without prior regulatory registration attracts seizure and confiscation; warehousing or re export claims do not cu...
Provisional release on security permitted where cash deposit plus bond secures differential duty; classification and treaty benefits referred for deci...
Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Integrated international transactions forming a single chain of product design, validation, manufacturing and sale were held to be benchmarkable under aggregated TNMM, and selective segregation of management, testing and validation services was rejected because the assessee's operating margin exceeded the comparable mean. The Transfer Pricing Officer could not fix arm's length price at nil without applying a recognised method, especially where records showed actual rendition of services. Outstanding receivables were treated as closely linked to the principal transaction and not separately benchmarked; with working capital adjustment already allowed and the assessee being debt-free, no notional interest adjustment survived. The appeal was allowed and the transfer pricing additions were deleted.
Integrated international transactions forming a single chain of product design, validation, manufacturing and sale were held to be benchmarkable under aggregated TNMM, and selective segregation of management, testing and validation services was rejected because the assessee's operating margin exceeded the comparable mean. The Transfer Pricing Officer could not fix arm's length price at nil without applying a recognised method, especially where records showed actual rendition of services. Outstanding receivables were treated as closely linked to the principal transaction and not separately benchmarked; with working capital adjustment already allowed and the assessee being debt-free, no notional interest adjustment survived. The appeal was allowed and the transfer pricing additions were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
