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CESTAT held that although the appellant and the buyer are inter-connected undertakings, the requisite legal relationship under Section 4(3)(b) and Rule 9 of the Valuation Rules (viz., distributorship/relatives or specified categories) was not established; consequently the deeming provisions treating them as related persons for valuation are inapplicable. The Tribunal further found no basis to classify the arrangement as a job-work transaction triggering Rule 10A valuation. The adjudicatory treatment of the supplies as related-party job work for enhanced valuation was therefore unsustainable. The impugned order confirming duty demands was set aside and the appeal allowed.
CESTAT held that although the appellant and the buyer are inter-connected undertakings, the requisite legal relationship under Section 4(3)(b) and Rule 9 of the Valuation Rules (viz., distributorship/relatives or specified categories) was not established; consequently the deeming provisions treating them as related persons for valuation are inapplicable. The Tribunal further found no basis to classify the arrangement as a job-work transaction triggering Rule 10A valuation. The adjudicatory treatment of the supplies as related-party job work for enhanced valuation was therefore unsustainable. The impugned order confirming duty demands was set aside and the appeal allowed.
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