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Royalty added to the transaction value of imported raw materials was held unsustainable where the same Technology Assistance Agreement had already been examined in the assessee's own case and the royalty was not shown to be a condition of sale of the imported goods. In the absence of any change in facts, documents, or law, the earlier valuation ruling was followed and the demand for differential customs duty could not be sustained. The consequential interest and penalty were also set aside, with relief allowed accordingly.
Royalty added to the transaction value of imported raw materials was held unsustainable where the same Technology Assistance Agreement had already been examined in the assessee's own case and the royalty was not shown to be a condition of sale of the imported goods. In the absence of any change in facts, documents, or law, the earlier valuation ruling was followed and the demand for differential customs duty could not be sustained. The consequential interest and penalty were also set aside, with relief allowed accordingly.
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