https://www.taxtmi.com/caselaws?id=428090 A mere difference between the transfer price of goods moved from the Puducherry unit and the price charged by a third-party supplier did not, by itself, justify an addition for alleged under-invoicing. The Tribunal noted that the internal transfers involved semi-finished goods requiring further processing at the Guwahati unit, so the apparent price gap had to be assessed with the additional processing cost in mind. It also found that the difference between total internal transfer cost and third-party purchase cost was marginal, and that the declared valuation had been accepted for central excise purposes. On that basis, the addition for alleged undervaluation was deleted. en-us Wed, 21 Sep 2022 00:00:00 +0530 Fri, 23 Sep 2022 08:26:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428090 A mere difference between the transfer price of goods moved from the Puducherry unit and the price charged by a third-party supplier did not, by itself, justify an addition for alleged under-invoicing. The Tribunal noted that the internal transfers involved semi-finished goods requiring further processing at the Guwahati unit, so the apparent price gap had to be assessed with the additional processing cost in mind. It also found that the difference between total internal transfer cost and third-party purchase cost was marginal, and that the declared valuation had been accepted for central excise purposes. On that basis, the addition for alleged undervaluation was deleted. Case-Laws Income Tax Wed, 21 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428090