https://www.taxtmi.com/caselaws?id=781652 CESTAT held that the contract manufacturers (CMs) were not the buyers of imported parts and components; the corporate principal is the beneficial owner. Royalty/license fees attributable to whole-device licensing are addable to transaction value under Rule 10(1)(c), duty may be demanded from the beneficial owner for the extended period, and interest on delayed duty is leviable. Goods are liable for confiscation under s.111(m). Penalty on the principal is limited to s.114A (not s.112 or s.114AA); CMs are liable under s.112(a) and s.114AA. Individual supervisory officer not penalised. Matter remanded to the original authority to redetermine penalties and differential duty. en-us Fri, 14 Nov 2025 00:00:00 +0530 Wed, 19 Nov 2025 08:52:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781652 CESTAT held that the contract manufacturers (CMs) were not the buyers of imported parts and components; the corporate principal is the beneficial owner. Royalty/license fees attributable to whole-device licensing are addable to transaction value under Rule 10(1)(c), duty may be demanded from the beneficial owner for the extended period, and interest on delayed duty is leviable. Goods are liable for confiscation under s.111(m). Penalty on the principal is limited to s.114A (not s.112 or s.114AA); CMs are liable under s.112(a) and s.114AA. Individual supervisory officer not penalised. Matter remanded to the original authority to redetermine penalties and differential duty. Case-Laws Customs Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781652