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    <title>2017 (9) TMI 1138 - CESTAT NEW DELHI</title>
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    <description>Royalty paid under a technical cooperation agreement was considered for inclusion in the assessable value of imported components under Rule 10(1)(c) of the Customs Valuation Rules, 2007. The analysis turned on whether the royalty, paid to a foreign collaborator under a separate licence arrangement, was an adjustment of the import price or merely consideration for know-how used in manufacture in India. It was noted that the technical assistance agreement and the supply contract had to be examined together, with competing Supreme Court authorities cited on royalty attribution. The impugned order was set aside and the matter remanded for fresh consideration and a de novo decision after hearing the appellants.</description>
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      <link>https://www.taxtmi.com/caselaws?id=348381</link>
      <description>Royalty paid under a technical cooperation agreement was considered for inclusion in the assessable value of imported components under Rule 10(1)(c) of the Customs Valuation Rules, 2007. The analysis turned on whether the royalty, paid to a foreign collaborator under a separate licence arrangement, was an adjustment of the import price or merely consideration for know-how used in manufacture in India. It was noted that the technical assistance agreement and the supply contract had to be examined together, with competing Supreme Court authorities cited on royalty attribution. The impugned order was set aside and the matter remanded for fresh consideration and a de novo decision after hearing the appellants.</description>
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