https://www.taxtmi.com/caselaws?id=470177 Inter-unit transfers of engines and engine kits to related units for manufacture of diesel generating sets are valued under Rule 10(a) read with the proviso to Rule 9 and Rule 8 of the Central Excise Valuation Rules, requiring valuation at 110% of production cost. Rule 4 cannot apply without comparable independent sales of identical goods at the nearest relevant time, and the substituted valuation rules apply retrospectively without sequential application. Where recipient units sell engines as such, Rule 9 transaction value applies. Extended limitation and penalties are not justified where returns, audit records and correspondence disclosed the valuation method, no wilful suppression exists, and duty is available as CENVAT credit, making transactions revenue-neutral. en-us Fri, 25 Oct 2024 00:00:00 +0530 Sat, 18 Jul 2026 20:46:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470177 Inter-unit transfers of engines and engine kits to related units for manufacture of diesel generating sets are valued under Rule 10(a) read with the proviso to Rule 9 and Rule 8 of the Central Excise Valuation Rules, requiring valuation at 110% of production cost. Rule 4 cannot apply without comparable independent sales of identical goods at the nearest relevant time, and the substituted valuation rules apply retrospectively without sequential application. Where recipient units sell engines as such, Rule 9 transaction value applies. Extended limitation and penalties are not justified where returns, audit records and correspondence disclosed the valuation method, no wilful suppression exists, and duty is available as CENVAT credit, making transactions revenue-neutral. Case-Laws Central Excise Fri, 25 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470177