TMI Blog2018 (2) TMI 1065X X X X Extracts X X X X X X X X Extracts X X X X ..... utely no justification to load the value of goods imported from Singapore on the basis of the profit margin of the Ireland unit. The transaction value between the foreign supplier and the respondent has been consistently accepted by the SVB and has been periodically renewed - transaction value must be accepted - appeal dismissed - decided against Revenue. - C/CROSS/20958/2016, C/Stay/20907/2016 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der-in-Original dt. 13/01/2016, the original adjudicating authority ordered for loading of imports as follows:- Name of the goods / items Addition percentage on the declared value I Phones 55.392% I Pad Mini 5.843% I Pod Classic 1.365% ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... also. In this connection Order-in-original No.1916/2004 dt. 20/04/2004, No.5896/2007 dt. 21/02/2007 and No.11306 dt. 09/03/2010 were passed for the earlier periods in which the invoice values were accepted. When the respondent commenced imports of Apple products from M/s. Apples Sales International, Ireland, Order-in-Original No.234/2011 dt. 01/10/2011 was issued; in this order also, the transact ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rgin was extremely low in comparison to the profit margin recorded by Apple, Ireland. Accordingly, in the original order, loading was ordered at percentages on the basis of profit margin of Apple, Ireland after deducting the profit margin of Apple, Singapore. 5. In the impugned order, the learned Commissioner(Appeals) has taken the view that such loading of the invoice value for goods imported ..... X X X X Extracts X X X X X X X X Extracts X X X X
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