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2019 (1) TMI 615 - AT - Central ExcisePenalty under erstwhile Section 11AC(1)(b) of the Act - penalty of 50% of the demand confirmed - valuation - change of opinion - suppression o facts or not - Held that:- The appellant have valued their goods as per their understanding, under Rule 8 which, is applicable in the case of related party or interconnected undertakings. Further, the demand of differential duty by the Revenue is by way of change of opinion that instead of Rule 8 Rule 4 is applicable, of the Valuation Rules. Thus, there is no suppression of facts and mis-conduct on the part of the appellant - penalty set aside - appeal allowed - decided in favor of appellant.
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