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...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Transfer pricing analysis under External TNMM remained the proper benchmarking method where the earlier remand had already excluded Internal TNMM and limited scrutiny to the comparables selected by the assessee. The text explains that mechanical turnover, export and product-difference filters could not justify wiping out the external comparable set for a limited-risk contract manufacturer earning a cost-plus return, and that comparable selection must reflect functions, assets and risks. It further states that AE and Non-AE segments were not internally comparable because the Non-AE business was entrepreneurial and risk-bearing, while audited segmental accounts could not be reworked absent specific defects. On that basis, the segmental results were restored and the transfer pricing adjustments were deleted.
Transfer pricing analysis under External TNMM remained the proper benchmarking method where the earlier remand had already excluded Internal TNMM and limited scrutiny to the comparables selected by the assessee. The text explains that mechanical turnover, export and product-difference filters could not justify wiping out the external comparable set for a limited-risk contract manufacturer earning a cost-plus return, and that comparable selection must reflect functions, assets and risks. It further states that AE and Non-AE segments were not internally comparable because the Non-AE business was entrepreneurial and risk-bearing, while audited segmental accounts could not be reworked absent specific defects. On that basis, the segmental results were restored and the transfer pricing adjustments were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
