CESTAT held that although the appellant and the buyer are...

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.