Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Misclassification between copra and dry coconut: customs recovery and re-valuation quashed for lack of prior licensing-authority invalidation, appeals...
Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years.
Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years.
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