https://www.taxtmi.com/caselaws?id=122601 Related-person valuation under Central Excise requires proof of mutuality of interest in each other's business, not merely common shareholding, common directors, control, or commercial dealings. Where two public limited companies remain distinct legal entities and the evidence does not show reciprocal business interest or extra-commercial consideration, they are not treated as related persons. In that situation, the seller's arm's length price cannot be discarded and the buyer's resale price cannot be substituted for assessable value. The text also notes that buyer-side commercial influence, bulk purchasing, branding, or expenditure on advertising and marketing does not by itself justify rejection of the transaction value. en-us Tue, 05 Jun 2007 00:00:00 +0530 Tue, 14 Aug 2012 18:17:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122601 Related-person valuation under Central Excise requires proof of mutuality of interest in each other's business, not merely common shareholding, common directors, control, or commercial dealings. Where two public limited companies remain distinct legal entities and the evidence does not show reciprocal business interest or extra-commercial consideration, they are not treated as related persons. In that situation, the seller's arm's length price cannot be discarded and the buyer's resale price cannot be substituted for assessable value. The text also notes that buyer-side commercial influence, bulk purchasing, branding, or expenditure on advertising and marketing does not by itself justify rejection of the transaction value. Case-Laws Central Excise Tue, 05 Jun 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122601