Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
The appellant had practice to pay the duty on provisional value at the time of removal of the goods and only on finalization of books of accounts the actual cost of manufacturing is arrived at and whenever there is a short of value, they were paying the differential duty - there is no suppression of facts and mala fide on the part of the appellants. Accordingly the demand for extended period is not sustainable.
The appellant had practice to pay the duty on provisional value at the time of removal of the goods and only on finalization of books of accounts the actual cost of manufacturing is arrived at and whenever there is a short of value, they were paying the differential duty - there is no suppression of facts and mala fide on the part of the appellants. Accordingly the demand for extended period is not sustainable.
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