https://www.taxtmi.com/caselaws?id=418701 Mere common shareholding, common directors, sole-selling arrangements, shared promotional expenses, or contractual restrictions do not by themselves establish related-person status under Central Excise valuation rules. The governing test is mutuality of interest in each other's business, requiring reciprocal interest rather than a one-sided commercial or managerial connection. On the facts, the entities dealt on principal-to-principal terms and the revenue material was insufficient to displace the declared transaction value. The appellants were therefore not related persons, the assessable value could not be re-fixed on the impugned basis, and the demand, interest, and penalties founded on rejection of transaction value failed. en-us Wed, 09 Feb 2022 00:00:00 +0530 Wed, 23 Feb 2022 08:26:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418701 Mere common shareholding, common directors, sole-selling arrangements, shared promotional expenses, or contractual restrictions do not by themselves establish related-person status under Central Excise valuation rules. The governing test is mutuality of interest in each other's business, requiring reciprocal interest rather than a one-sided commercial or managerial connection. On the facts, the entities dealt on principal-to-principal terms and the revenue material was insufficient to displace the declared transaction value. The appellants were therefore not related persons, the assessable value could not be re-fixed on the impugned basis, and the demand, interest, and penalties founded on rejection of transaction value failed. Case-Laws Central Excise Wed, 09 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418701