https://www.taxtmi.com/caselaws?id=118428 Under the Customs (Valuation) Rules, 1988, a buyer and an assessee are not "related persons" merely because the buyer holds a substantial shareholding in the assessee. In the absence of reciprocal shareholding, direct or indirect control, or other evidence of mutuality of interest, Rule 2(2) is not satisfied and the declared transaction value cannot be rejected. The department's attempt to invoke a different clause not covered by the show-cause notice also failed. On those facts, the transaction value was correctly accepted and the valuation challenge could not succeed. en-us Wed, 12 Jul 2006 00:00:00 +0530 Sat, 30 Jun 2012 15:53:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=118428 Under the Customs (Valuation) Rules, 1988, a buyer and an assessee are not "related persons" merely because the buyer holds a substantial shareholding in the assessee. In the absence of reciprocal shareholding, direct or indirect control, or other evidence of mutuality of interest, Rule 2(2) is not satisfied and the declared transaction value cannot be rejected. The department's attempt to invoke a different clause not covered by the show-cause notice also failed. On those facts, the transaction value was correctly accepted and the valuation challenge could not succeed. Case-Laws Customs Wed, 12 Jul 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=118428