2016 (11) TMI 86

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....st Order-in- Appeal No.  464/2005/MCH/DC/ GVC/05 dated  15.09.2005. 2. Heard both sides and perused the records. 3. On perusal of the records, it is noticed that the issue involved in this case is regarding the inclusion of royalty amount paid by appellant to M/s. Ford Motor Company, USA as a collaborator for the technical know-how.  It is the case of the revenue that the appellan....

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....the first appellate authority. 4. We find from the records that the appellant has produced a certificate of the CA which categorically states that the royalty payment made by the appellant to M/s. Ford Motor Company, USA is excluding the amount/sales of the Mondeo cars. 5. We also find from the records that the appellant had clearly stated before the lower authorities that the Ford Mondeo cars i....