2016 (11) TMI 814

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....nbsp; Chatru Singh, Asstt. Commissioner(A.R.) for the Respondent ORDER The appellant, M/s. Kirloskar Abara Pumps Ltd entered into an agreement  with Ebara Corporation, Japan. Collaboration agreement involved payment of royalty.  The matter was taken up by Gatt Valuation Cell.  After examining the contract the Dy Commissioner held that price has not been influenced by the relat....

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....n it has been stated that  price of the goods  to general customers and Ebara Group Manufacturing companies is one and the same.  He argued that Dy Commissioner has observed that that the condition of sale is absent  in the agreement and therefore  royalty payment cannot be added to the value. 3.  Ld. A.R. pointed out that the Commissioner (Appeals) has only remand....

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....heir appeal have not submitted copy of collaboration  agreement however article 'x'  has been reproduced on page 9 of the appeal.  The said article reads as follow: "Component Parts Licensee shall purchase from EBARA, and EBARA shall sell to LICENSEE, at EBARA's  regular price, component part, accessories  or attachments of the Products which are available  for ....