https://www.taxtmi.com/caselaws?id=109480 Valuation under the related-person provisions requires the Revenue to establish both the statutory relationship and mutuality of interest on the basis of the original notice and evidence. A joint venture was not shown to be a related person, as the entities were separate legal persons dealing on principal-to-principal terms. Price reduction could not be treated as undervaluation where earlier clearances were direct sales to actual users and later clearances were through a wholesale channel with different post-sale obligations. New theories raised in appeal, including that the buyer was not a buyer or that price was depressed by technical know-how, were rejected because they changed the basis of the demand. Ancillary objections on limitation and the unsigned Board order did not alter the result. en-us Fri, 28 Mar 2003 00:00:00 +0530 Tue, 10 Apr 2012 14:15:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=109480 Valuation under the related-person provisions requires the Revenue to establish both the statutory relationship and mutuality of interest on the basis of the original notice and evidence. A joint venture was not shown to be a related person, as the entities were separate legal persons dealing on principal-to-principal terms. Price reduction could not be treated as undervaluation where earlier clearances were direct sales to actual users and later clearances were through a wholesale channel with different post-sale obligations. New theories raised in appeal, including that the buyer was not a buyer or that price was depressed by technical know-how, were rejected because they changed the basis of the demand. Ancillary objections on limitation and the unsigned Board order did not alter the result. Case-Laws Central Excise Fri, 28 Mar 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=109480