Related person finding under customs valuation rules sustained; departmental challenge failed for lack of material.

Importers were treated as related to the supplier under Rule 2(2)(iv) of the Customs Valuation Rules, 1988, after the lower appellate authority reversed the original authority's contrary finding on the facts and the rule. The tribunal found no material in the department's grounds of appeal or submissions to disturb that conclusion. The relationship finding therefore remained undisturbed, and the departmental appeal was rejected.

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Issues: Whether the importers were related to the supplier within the meaning of Rule 2(2)(iv) of the Customs Valuation Rules, 1988, and whether the lower appellate authority was right in reversing the original authority's finding on that question.

Analysis: The original authority had held that the importers were related to the supplier under Rule 2(2)(iv) of the Customs Valuation Rules, 1988. The lower appellate authority reversed that finding after considering the facts and the rule. The appellate tribunal found no evidence in the grounds of appeal or in the submissions to disturb the lower appellate authority's conclusion.

Conclusion: The finding that the importers were related to the supplier was not interfered with, and the department's appeal was rejected.

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