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    <title>2026 (7) TMI 476 - CESTAT CHENNAI</title>
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    <description>Royalty under a technology assistance agreement was held outside the transaction value of imported raw materials because it was not shown to be a condition of import or sale and no direct nexus with the goods was established; the royalty was linked to manufacture and sale of finished products. The extended period for demanding differential duty was also found unsustainable because the department had full knowledge of the arrangement, the relevant documents had been furnished over the years, and no suppression of facts, new material, or change in law was shown. On these grounds, the demand failed and consequential relief followed.</description>
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