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    <title>2026 (7) TMI 993 - CESTAT BANGALORE</title>
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    <description>Separate corporate entities are not treated as related persons for Central Excise valuation solely because they operate under common management. The proposed related-person valuation was also revenue-neutral because duty paid by the supplying unit would be available as input credit to the receiving unit, making the consequential demand unsustainable. Extended limitation cannot be invoked where the Department already knew the units&#039; ownership, management and activities through registrations, returns and visits, and suppression with intent to evade duty is not established. The demand, interest and penalty based on those grounds could not be sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=795107</link>
      <description>Separate corporate entities are not treated as related persons for Central Excise valuation solely because they operate under common management. The proposed related-person valuation was also revenue-neutral because duty paid by the supplying unit would be available as input credit to the receiving unit, making the consequential demand unsustainable. Extended limitation cannot be invoked where the Department already knew the units&#039; ownership, management and activities through registrations, returns and visits, and suppression with intent to evade duty is not established. The demand, interest and penalty based on those grounds could not be sustained.</description>
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