2015 (2) TMI 597

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....cate For the Respondent : Mr. R. Gurunathan, AR ORDER Per: B.S.V. MURTHY The facts of the case in brief are that the importer-appellant imported goods from their overseas supplier M/s. ZIV Applications Y Technologia, S.L. of Spain and its manufacturing units elsewhere (suppliers). The appellant is a joint venture of cargo and M/s. JIV and the matter was referred to Special Valuation Br....

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....its that according to Rule 10(c), addition can be made only when royalty and technical knowhow are paid as a condition of sale. He takes us through the agreement to show that there is no relationship between the sale and the technical know how fees and royalty paid by them. He submits that the appellant is yet to commence manufacturing operations and therefore there cannot be any link between manu....