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The CESTAT held that Rule 6(b)(ii) of the Valuation Rules does not apply to imported raw materials used as inputs that were not manufactured by either unit and merely routed through an intermediate unit without undergoing any process resulting in excisable goods. The Revenue failed to establish that the inputs were processed into excisable goods before transfer. Consequently, the loading of notional profit under Rule 6(b) was unwarranted. The impugned order directing such loading was set aside, and the appeal was allowed.
The CESTAT held that Rule 6(b)(ii) of the Valuation Rules does not apply to imported raw materials used as inputs that were not manufactured by either unit and merely routed through an intermediate unit without undergoing any process resulting in excisable goods. The Revenue failed to establish that the inputs were processed into excisable goods before transfer. Consequently, the loading of notional profit under Rule 6(b) was unwarranted. The impugned order directing such loading was set aside, and the appeal was allowed.
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