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Valuation of imported goods - addition of franchise fee and international marketing charges incurred and of services obtained, in transaction value - The tribunal’s insistence on strict compliance with procedural fairness and the need for clear factual and legal grounds to support customs authority actions reflect a judicial approach that balances enforcement with fairness to the trading community. The judgment also highlights the evolving nature of international trade and the challenges customs authorities face in keeping pace with complex commercial arrangements. - The matters were remanded to the original authority for a fresh examination of the justification for invoking the extended period and the accurate quantification of the demand.