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of Valuation - undervaluation - “Polo” and “Vento” models of their car - related party transaction - interconnected undertakings - Mutuality of Interest - It is found that the transaction value is not determined by the appellant, but the transfer value claimed to be the true transaction value is determined by the Planning Round, every year which is headed by M/s VWAG, Germany. - if corporate veil is pierced then we find that the entire operations of manufacture and sale of these vehicle was throughout on account of M/s VWAG, Germany. - By application of Rule 11, in case of related person transactions the value needs to be determined by application of Rule 9 - AT
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