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Valuation of goods - related party - inter-connected undertakings - They are inter-connected undertakings and hence are related in terms of Clause (i) of Explanation to Section 4 (3) (b), they are not related in terms of Clause (ii) (iii) or (iv). - As Rule 10 (b) squarely covers the transaction, value has to be determined as per this Rule. - it should be assessed as if the assessee and the buyer are not related persons - AT