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Provisions expressly mentioned in the judgment/order text.
Valuation- inter-connected undertaking - related parties or not - applicability of doctrine of mutuality of interest - The fact that Appellant 1 and Appellant 2 were not related person has been brought out in the cost auditor report received by the department on 31.12.2007, as recorded while recording the submissions of the appellant in the impugned order - this cost auditor report has not been placed on record by either side but if the cost auditor report had concluded that the Appellants were not related then definitely Commissioner should have recorded the reasons for rejecting the said report. - AT
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