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    <title>2026 (4) TMI 146 - CESTAT BANGALORE</title>
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    <description>Where job-worked finished goods are sold by the principal manufacturer to the job worker at the time of removal, and the buyer is unrelated with price as the sole consideration, Rule 10A(i) governs valuation and the declared transaction value must be accepted. The department cannot reject that value and resort to Rule 11 without transaction-specific evidence. A uniform profit loading, including a 41.48% margin, was unsupported where no comparable transactions were identified and the CAS-4 cost data supported the declared price. The valuation rework was therefore unjustified and the consequential duty demand could not stand.</description>
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      <description>Where job-worked finished goods are sold by the principal manufacturer to the job worker at the time of removal, and the buyer is unrelated with price as the sole consideration, Rule 10A(i) governs valuation and the declared transaction value must be accepted. The department cannot reject that value and resort to Rule 11 without transaction-specific evidence. A uniform profit loading, including a 41.48% margin, was unsupported where no comparable transactions were identified and the CAS-4 cost data supported the declared price. The valuation rework was therefore unjustified and the consequential duty demand could not stand.</description>
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