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    <description>Disclosure of the conversion arrangement in invoices and records, together with provisional assessments already covering much of the period, meant the department had the relevant material to examine valuation in time; the extended period of limitation was therefore not available absent proof of suppression or intent to evade. For clearances to an effectively controlled associated company, the parties were treated as related, so the applicable cost-based valuation rule governed and the ordinary job-work valuation approach was inapplicable. On that basis, the duty demand and connected penalties were unsustainable, and complete relief followed on both limitation and merits.</description>
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