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(1) For the purpose of ascertaining whether a person has willfully misrepresented the cost of goods or services provided abroad, the Court shall determine-

(a) the normal commercial cost of the goods or services provided in their country of origin and in the case of the goods taking into account the fact that they are intended for export;

(b) the amount of foreign exchange transferred in payment for those goods or services.

(2) The amount by which the foreign exchange transferred in payment for the goods or services in question exceeds their normal commercial cost shall be deemed to be an amount transferred by willful misrepresentation.