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    <title>2025 (8) TMI 253 - CESTAT CHENNAI</title>
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    <description>Rule 6(b)(ii) of the Central Excise Valuation Rules, 1975 applies only where excisable goods are not sold and are used or consumed by or on behalf of the assessee in the manufacture of other articles, with valuation then based on comparable goods or, failing that, cost of production including profit. On the stated facts, imported raw materials were transferred to a sister unit and there was no evidence that they had become excisable goods before transfer or that the statutory precondition for captive-consumption valuation was met. The mere common ownership of the units was insufficient. Accordingly, loading of notional profit was held unjustified and the revenue&#039;s valuation approach could not be sustained.</description>
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      <description>Rule 6(b)(ii) of the Central Excise Valuation Rules, 1975 applies only where excisable goods are not sold and are used or consumed by or on behalf of the assessee in the manufacture of other articles, with valuation then based on comparable goods or, failing that, cost of production including profit. On the stated facts, imported raw materials were transferred to a sister unit and there was no evidence that they had become excisable goods before transfer or that the statutory precondition for captive-consumption valuation was met. The mere common ownership of the units was insufficient. Accordingly, loading of notional profit was held unjustified and the revenue&#039;s valuation approach could not be sustained.</description>
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