Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
A written acceptance of enhanced customs value does not, by itself, extinguish an importer's statutory right to challenge reassessment; where letters show protest and the authority failed to consider them, rejection of the appeal on the sole ground of consent was unsustainable. Declared transaction value also cannot be rejected and redetermined without communicating written reasons for doubt and following the mandatory valuation procedure, and mere reference to contemporaneous import data or NIDB entries is insufficient without particulars and procedural compliance. The enhancement of value and consequential appellate orders were therefore set aside, and the appeals were allowed with consequential relief.
A written acceptance of enhanced customs value does not, by itself, extinguish an importer's statutory right to challenge reassessment; where letters show protest and the authority failed to consider them, rejection of the appeal on the sole ground of consent was unsustainable. Declared transaction value also cannot be rejected and redetermined without communicating written reasons for doubt and following the mandatory valuation procedure, and mere reference to contemporaneous import data or NIDB entries is insufficient without particulars and procedural compliance. The enhancement of value and consequential appellate orders were therefore set aside, and the appeals were allowed with consequential relief.
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