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    <title>2022 (9) TMI 23 - CESTAT MUMBAI</title>
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    <description>PMC, not MEGPTCL, was treated as the importer because PMC filed the Bills of Entry and paid duty, while the later beneficial owner amendment did not apply retrospectively. The Department&#039;s foreign bank documents were inadmissible because the required certificate and proof of authenticity were absent, so they could not support the demand. Declared transaction value could not be rejected in the absence of reliable evidence of related-party influence or over-valuation, especially where the contract was awarded through international competitive bidding and contemporaneous project data supported the price. For project imports, the registered contract was the correct unit of assessment, and confiscation and penalties could not survive once over-valuation was not proved.</description>
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