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Amendment in Rule 8 supports appellant's case; valuation changes apply from Dec 10, 2013, not retroactively.
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....Valuation of goods - finished goods cleared to interconnected sister units - The legislators keeping in mind and accepting the interpretation of valuation provision made in the judgments supra, brought an amendment in Rule 8 and the same is effective from 10.12.2013. This amendment in Rule 8 further strengthen the case of the appellant in their favour. Needless to state that the said amendment cannot be applied retrospectively. For the above reason also the contention of the revenue is not sustainable. - AT....