TP Adjustment - upward adjustment - import of goods - Royalty -...

TP Adjustment - upward adjustment - import of goods - Royalty - The Special Valuation Branch of the Customs Authorities has given a categorical finding that royalty is not included in the invoice value of the goods imported by the assessee - while arriving at a conclusion, ld. TPO has no where recorded and referred to any material which could demonstrate that royalty payment by the assessee is embedded in the process of the imported goods. - Additions deleted - AT