https://www.taxtmi.com/caselaws?id=418702 In a contract-manufacturing arrangement on a principal-to-principal basis, buyer specifications, formulations, artwork, brand ownership, inspection rights and approval of artwork were treated as ordinary commercial terms and not additional consideration for valuation. The department could not justify enhancement of assessable value by adopting the buyer's selling price, and the absence of proof of extra-commercial flowback or related-person status meant Rule 6 and Rule 9 were inapplicable. The text also notes that where the arrangement, agreement and refund claims were already within departmental knowledge and audits were conducted, suppression or intent to evade duty is not established, so the extended limitation period cannot be invoked. en-us Tue, 22 Feb 2022 00:00:00 +0530 Wed, 23 Feb 2022 08:26:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418702 In a contract-manufacturing arrangement on a principal-to-principal basis, buyer specifications, formulations, artwork, brand ownership, inspection rights and approval of artwork were treated as ordinary commercial terms and not additional consideration for valuation. The department could not justify enhancement of assessable value by adopting the buyer's selling price, and the absence of proof of extra-commercial flowback or related-person status meant Rule 6 and Rule 9 were inapplicable. The text also notes that where the arrangement, agreement and refund claims were already within departmental knowledge and audits were conducted, suppression or intent to evade duty is not established, so the extended limitation period cannot be invoked. Case-Laws Central Excise Tue, 22 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418702