Supplier's 5% Shareholding in Importer Doesn't Automatically Make Them Related; Misinterpretation of Rule 2(2)(iv.

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....Transaction value - Related person – The interpretation given by the original authority would amount to re-writing of Rule 2(2)(iv) to read that if the supplier has more than 5% of the shares in the importing company, then both would be deemed to be related. There is no warrant in law to do so. - AT....