TaxTMI 
TaxTMI 
2017 (6) TMI 1068
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....sioner (A.R) for respondent ORDER The appellants are engaged in the manufacture of Welding Machines and parts thereof falling under Chapter 8515.00 of the First Schedule to the Central Excise Tariff Act, 1985. For the manufacture and clearance of welding machines to various independent customers the appellant obtained design and development from M/s. Ador Powertron Industries Ltd. The show cause....
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.... design and development which was used in the manufacture of welding machine was received by the appellant on principal to principal basis from their sister concern M/s. Ador Powertron Industries Ltd. for which they have made the payment of Rs. 24,09,524/- in the year 1998-99. The said amount is expenses of the appellant which has been accounted for in their profit and loss account. He submits tha....
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....ot under dispute that the appellant are manufacturing and selling their welding machines to independent unrelated buyers on a transaction value. The design and development service was not received by the appellant from their customer free of cost. The design and development services was received by the appellant from their sister concern on principal to principal basis on payment towards such serv....