https://www.taxtmi.com/caselaws?id=417839 Commercially agreed Import Parity Price under an inter se supply arrangement between independent entities was treated as the transaction value for petroleum product clearances, because the memorandum of understanding reflected a sale and purchase structure with payment terms, not a related-party transfer. The mere existence of a mutually beneficial arrangement did not create a related-person relationship under the Central Excise Act, and the evidence did not support recharacterising the deal as a product-sharing or loan-debt arrangement. The adjudication also could not rest on grounds beyond those alleged in the show cause notice. The valuation adopted by the assessee was upheld and substitution of the related holding company's valuation was rejected. en-us Tue, 01 Feb 2022 00:00:00 +0530 Thu, 03 Feb 2022 07:33:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417839 Commercially agreed Import Parity Price under an inter se supply arrangement between independent entities was treated as the transaction value for petroleum product clearances, because the memorandum of understanding reflected a sale and purchase structure with payment terms, not a related-party transfer. The mere existence of a mutually beneficial arrangement did not create a related-person relationship under the Central Excise Act, and the evidence did not support recharacterising the deal as a product-sharing or loan-debt arrangement. The adjudication also could not rest on grounds beyond those alleged in the show cause notice. The valuation adopted by the assessee was upheld and substitution of the related holding company's valuation was rejected. Case-Laws Central Excise Tue, 01 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417839