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of CESTAT allowed the appeal, finding no valid basis for rejecting the declared customs value. The tribunal determined that no additional consideration was paid, the invoice for services was cancelled, and no actual payment occurred. The commissioner failed to follow prescribed procedural requirements under section 138B. Consequently, the tribunal invalidated the duty reassessment, goods confiscation, and penalties, particularly noting that penalties against foreign entities were unsustainable as the Customs Act's jurisdiction did not extend extraterritorially during the relevant period.
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