Court Rules on Duty Levy: Profit Inclusion in Assessable Value for Goods to Sister Unit, Considers Revenue Neutrality and Limitation.

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....Extended Period of limitation - Revenue Neutrality - The issue involved is also of pure interpretation of provisions of levy of duty including profit in assessable value in clearance of goods to sister unit for captive use. In such facts of case, it cannot be said that the Appellant had any mala fide intentions to evade payment of duty, which otherwise was available to Appellant as Cenvat Credit in sister unit and that Appellant have not suppressed assessable value with intention to evade payment of duty. - AT....