Countervailing Duty on Set-Top Boxes to Be Based on Transaction Value, Not Retail Sale Price: No Ownership Transfer Involved.

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....Valuation of imported STBs for the purpose of levy of CVD - Transaction Value or Retail Sale Price (RSP) - There is no element of sale involved in as much as the ownership of the STBs were never passed on by the appellants to the subscribers. Thus, in absence of any element of sale i.e., transfer of property in goods from one person to another, the question of affixation of RSP in the packages would not arise and if the importer choose to do so, the same cannot be questioned, in the absence of any specific statutory provisions in vogue, restricting such practice - CVD has to be assessed in general on the transaction value - AT....