TaxTMI 
TaxTMI 
2016 (11) TMI 814
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....er(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 relationship. He also held that the appe....
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....e 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 remanded the matter back to the original adjudicati....
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....ation 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 sale by EBARA and which the LICENSEE is not a....