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    <title>2002 (12) TMI 137 - CEGAT, BANGALORE</title>
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    <description>Mutuality of interest was not established merely from references to transfer pricing, group control, collection of dues, or integrated sales and marketing, because those materials did not show that the assessee had a direct or indirect interest in BPL Ltd.&#039;s business or that the dealings were not at arm&#039;s length. The Tribunal also noted that both entities were separate public limited companies, the sales were ordinary commercial sales, and the Revenue had not shown that title in the goods did not pass on sale. On those facts, BPL Ltd.&#039;s dealer price could not be used to rework the assessable value under Section 4 of the Central Excise Act, 1944.</description>
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    <pubDate>Fri, 13 Dec 2002 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=51660</link>
      <description>Mutuality of interest was not established merely from references to transfer pricing, group control, collection of dues, or integrated sales and marketing, because those materials did not show that the assessee had a direct or indirect interest in BPL Ltd.&#039;s business or that the dealings were not at arm&#039;s length. The Tribunal also noted that both entities were separate public limited companies, the sales were ordinary commercial sales, and the Revenue had not shown that title in the goods did not pass on sale. On those facts, BPL Ltd.&#039;s dealer price could not be used to rework the assessable value under Section 4 of the Central Excise Act, 1944.</description>
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