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    <title>2026 (2) TMI 664 - CESTAT BANGALORE</title>
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    <description>Undervaluation allegations based on related-person or inter-connected undertaking treatment were rejected because the record did not establish the necessary mutuality of interest or flow back of consideration, so transaction value remained acceptable. The goods were also held to be classifiable as automatic data processing systems under Chapter heading 8471, since their functions included data acquisition, processing, display and output rather than mere testing or measuring. The alleged short payment for March 2017 failed on invoice reconciliation, and the extended period of limitation was unavailable because departmental audits, scrutiny and recorded statements showed prior knowledge of the relevant facts. The demand, reclassification and penalty therefore could not be sustained.</description>
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      <description>Undervaluation allegations based on related-person or inter-connected undertaking treatment were rejected because the record did not establish the necessary mutuality of interest or flow back of consideration, so transaction value remained acceptable. The goods were also held to be classifiable as automatic data processing systems under Chapter heading 8471, since their functions included data acquisition, processing, display and output rather than mere testing or measuring. The alleged short payment for March 2017 failed on invoice reconciliation, and the extended period of limitation was unavailable because departmental audits, scrutiny and recorded statements showed prior knowledge of the relevant facts. The demand, reclassification and penalty therefore could not be sustained.</description>
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