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...
SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
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