Burden to prove depressed price governs valuation interference, with the issue decided in favour of the assessee.

The Department must discharge the burden of showing that the price was depressed before interference with valuation is justified. On the facts stated, that burden was not discharged, and the appeals were treated as covered by an earlier Supreme Court decision. The issue was therefore answered against the Revenue and in favour of the assessee.

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Issues: Whether the Department had discharged the burden to show that the price was depressed so as to justify interference with the valuation.

Analysis: The appeals were stated to be covered by an earlier decision of the Supreme Court. It was also accepted that, on the facts of these appeals, the Department had not discharged the burden of showing that the price had been depressed.

Conclusion: The issue was answered against the Revenue and in favour of the assessee.

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