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    <title>2024 (2) TMI 1096 - CESTAT BANGALORE</title>
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    <description>Declared transaction value under the Customs Valuation Rules cannot be rejected merely because buyer and seller are related or because discounts are shown, if the proper officer lacks reasonable doubt supported by evidence that the relationship influenced price; here, marginal price variation, worldwide pricing consistency and no evidence of flow-back meant rejection was unjustified. Royalty is includible in assessable value only where it is linked to the imported goods and forms a condition of their sale; here, the royalty related to technology used in Indian manufacture, not to the imported finished goods, so it was not includible. The valuation rejection and royalty addition were therefore unsustainable.</description>
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      <description>Declared transaction value under the Customs Valuation Rules cannot be rejected merely because buyer and seller are related or because discounts are shown, if the proper officer lacks reasonable doubt supported by evidence that the relationship influenced price; here, marginal price variation, worldwide pricing consistency and no evidence of flow-back meant rejection was unjustified. Royalty is includible in assessable value only where it is linked to the imported goods and forms a condition of their sale; here, the royalty related to technology used in Indian manufacture, not to the imported finished goods, so it was not includible. The valuation rejection and royalty addition were therefore unsustainable.</description>
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