Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Enhancement of the assessable value of imported old and used machines could not be sustained where the local Chartered Engineer certificate was issued without opening and examining the goods. The Tribunal noted that the goods had already been examined and released on the basis of the load port certificate furnished by the importer, while the later local certificate, used to finalise provisional assessment and raise differential duty, pre-dated the 100% examination and therefore lacked evidentiary validity. On that basis, the value enhancement was held legally unsustainable, and the consequential customs duty demand with interest was set aside.
Enhancement of the assessable value of imported old and used machines could not be sustained where the local Chartered Engineer certificate was issued without opening and examining the goods. The Tribunal noted that the goods had already been examined and released on the basis of the load port certificate furnished by the importer, while the later local certificate, used to finalise provisional assessment and raise differential duty, pre-dated the 100% examination and therefore lacked evidentiary validity. On that basis, the value enhancement was held legally unsustainable, and the consequential customs duty demand with interest was set aside.
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