Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
