2001 (5) TMI 118

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....ankar, Member (T)]. - The common question for consideration in these two appeals is whether the notional interest on the advance payment of the price paid by the buyer to each of the appellant manufacturers should be added to the assessable value of the goods. The Commissioner (Appeals), Mumbai in Appeal E/1583/96 and Commissioner (Appeals), Pune in Appeal E/1625/96 both held it to be includable. ....

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.... tailor-made goods, that the fact of advance has depressed the price, does not relieve it from establishing the required nexus between the fact of the advance, and a reduction in price. The Tribunal has also held in a number of cases that the fact that advances were taken the manufacturer is relieved from resorting to commercial borrowing is too remote to establish the required nexus. [C.C.E. v. C....