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...
Amounts paid for technical know-how, engineering and post-importation assistance are includible in assessable value only if they are shown to be a condition of sale of the imported goods. The contract here separately allocated obligations and consideration between technical services and supply of key equipment, with separate invoices and no contractual nexus proving that the services were a precondition for purchase of the imported machinery. The Tribunal therefore held that the separately contracted licence, engineering and technical assistance charges were not part of the transaction value of the imported plant and equipment, and could not be added to assessable value.
Amounts paid for technical know-how, engineering and post-importation assistance are includible in assessable value only if they are shown to be a condition of sale of the imported goods. The contract here separately allocated obligations and consideration between technical services and supply of key equipment, with separate invoices and no contractual nexus proving that the services were a precondition for purchase of the imported machinery. The Tribunal therefore held that the separately contracted licence, engineering and technical assistance charges were not part of the transaction value of the imported plant and equipment, and could not be added to assessable value.
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