High Seas Sales Value Must Be Included in Transaction Value for Works Contract Services, Says Legal Analysis.

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....Valuation - work contract service - The applicant, in terms of the contract, is liable to provide the goods [supplied on HSS basis] and hence the submission that this value is not to be included in the transaction value in respect of works contract service is legally not tenable more so since the applicant is contractually bound/liable to supply both the goods and the services. - AAR....