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of CESTAT ruled that royalty and technical fees paid by appellant to foreign supplier were not includible in transaction value of imported goods under Rule 10(1)(c) of CVR 2007. While analyzing the technical assistance agreement, tribunal found only 9% of final product value came from imports. The agreement primarily covered technical personnel deployment for obtaining product approvals from Company H, with no direct connection to imported raw materials. Following precedents in Company B and Company BB cases, CESTAT held that absent clear nexus between royalty payments and imported goods as condition of sale, such payments cannot be added to transaction value. Differential customs duty demand set aside and appeal allowed.
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