Customs Valuation & SVB
Every related-party importer in India operates under a standing question: has the relationship influenced the price? The Special Valuation Branch exists to ask it formally, and the proceedings arrive sooner or later for any foreign group supplying its Indian affiliate. Handled well, SVB concludes with prices accepted and shipments flowing. Handled badly, it produces provisional assessments with extra-duty deposits, cash-flow drag across every import, and an open exposure that renews itself for years.
The technical difficulty is real: customs valuation and transfer pricing pull in opposite directions — customs suspects prices are too low, income tax suspects they are too high — and an SVB submission that ignores your TP positions can win one battle by losing the other. We prepare submissions that reconcile the two regimes: documented pricing methodology, benefit and substance evidence for the additions customs scrutinises (royalties, licence fees, cost contributions), and consistency with the TP file that another wing of the same government already holds.
What this covers
- SVB submissions and renewals: questionnaires, annexures, and methodology documentation prepared to acceptance standard.
- Customs–transfer pricing reconciliation, so neither regime's file indicts the other's.
- Royalty and licence-fee analysis under Rule 10: when they are addable to customs value and how to defend when they are not.
- Provisional assessment management: minimising deposit drag while proceedings run.
- Loading disputes: technical defense when the department proposes to enhance declared values.
Who needs this
Indian subsidiaries importing from group companies; foreign parents setting intercompany prices for Indian supply; and importers already in provisional assessment who need proceedings closed.
How we deliver
- Pre-submission reconciliation of customs values against transfer pricing policy and documentation.
- SVB questionnaire and annexure preparation to acceptance standard, with renewals calendared.
- Provisional assessment management minimising deposit drag while proceedings conclude.
Why A2 Consultants
We run customs valuation and transfer pricing inside one firm — the two regimes that judge your import prices from opposite directions are answered with one consistent story, which is the only defense that works for both.
Engagement & what to expect
SVB engagements begin with reconciliation: your customs values, transfer pricing policy, and intercompany agreements read together before the department reads them separately. Submission preparation runs four to eight weeks depending on flow complexity, with the questionnaire, annexures, and methodology documentation built to acceptance standard. Where proceedings are already open, we take over provisional assessment management and query response. The engagement concludes with the SVB order — and typically continues as renewal-cycle management, since related-party importers are never really done with valuation.
SVB is not optional for related-party importers — the only choice is whether you meet it prepared or provisional.