Commissioner (Appeals) Decision Overturned: Relationship Impact on Invoice Pricing in Import Valuation Insufficiently Demonstrated.

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....Valuation of imported goods - related persons - Subvention payments by a parent company to its loss making subsidiary - We find that original authority had given findings based on analysis. If the Commissioner (Appeals) found some reason to conclude otherwise, he could have so decided after pointing out how the relationship affected the invoice price and what elements should be added to the invoice price to arrive at the value but he did not. - The order passed by the Commissioner (Appeals) allowing the appeal filed by the Department and setting aside the order-in-original cannot be sustained - AT....