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CESTAT held that while the impugned goods supplied to the Railways were marketable and not entitled to a government-company exemption, the adjudicating authority erred in invoking Valuation Rules (notably Rules 11 and 8) without adequate reasoning and in disregarding the appellants' CAS-4 cost records. The Tribunal found the valuation adjustments and differential duty computation unsustainable because the authority failed to explain why the appellants' declared value was incorrect and did not properly apply s.4(1) principles. Consequently the impugned orders were set aside, differential duty was not sustained, and penalties were held unwarranted. Both appeals were allowed in favour of the appellants.
CESTAT held that while the impugned goods supplied to the Railways were marketable and not entitled to a government-company exemption, the adjudicating authority erred in invoking Valuation Rules (notably Rules 11 and 8) without adequate reasoning and in disregarding the appellants' CAS-4 cost records. The Tribunal found the valuation adjustments and differential duty computation unsustainable because the authority failed to explain why the appellants' declared value was incorrect and did not properly apply s.4(1) principles. Consequently the impugned orders were set aside, differential duty was not sustained, and penalties were held unwarranted. Both appeals were allowed in favour of the appellants.
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