https://www.taxtmi.com/caselaws?id=34864 Related-person valuation under Section 4 requires proof that the buyer and seller each have a direct or indirect interest in the other's business; a mere holding-subsidiary relationship is insufficient without mutuality of interest. Fully convertible debentures were treated as a commercial investment transaction, not financial accommodation or an interest-free loan, and no other material showed related-person status. In the absence of mutuality, the actual transaction value could not be rejected in favour of higher comparable prices from other manufacturers, and the higher valuation was unsupported on the record. As the demand failed, the consequential penalty could not survive. en-us Fri, 13 Feb 2009 00:00:00 +0530 Thu, 05 Nov 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=34864 Related-person valuation under Section 4 requires proof that the buyer and seller each have a direct or indirect interest in the other's business; a mere holding-subsidiary relationship is insufficient without mutuality of interest. Fully convertible debentures were treated as a commercial investment transaction, not financial accommodation or an interest-free loan, and no other material showed related-person status. In the absence of mutuality, the actual transaction value could not be rejected in favour of higher comparable prices from other manufacturers, and the higher valuation was unsupported on the record. As the demand failed, the consequential penalty could not survive. Case-Laws Central Excise Fri, 13 Feb 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34864