TMI Blog2018 (10) TMI 1321X X X X Extracts X X X X X X X X Extracts X X X X ..... acture, on the contrary the appellant have submitted a Chartered Accountant Certificate wherein the cost data was certified which shows that the value as per cost certificate is less than the value charged by the appellant to their customer. They have further obtained a certificate from Cost Accountant which has endorsed the certification of the Chartered Accountant regarding cost of manufacture p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Per: Ramesh Nair The case of the department is that the appellant have supplied the goods to their sister concern which is related in terms of Section 4 of the Central Excise Act, 1944. The goods were sold on the transaction value. The department s contention is that since the goods were supplied to the related person, valuation under Rule 8 and Proviso to Rule 9 of Central Excise Val ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is not acceptable, they have taken further Certification from Cost Accountant, who certify that the cost certified by the Chartered Accountant is correct. Therefore, there is no reason for disputing the value adopted by the appellant. He also submits that the demand is time bar on the ground that there is Revenue neutral situation because the duty paid by the appellant has been taken as a Cenvat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was certified which shows that the value as per cost certificate is less than the value charged by the appellant to their customer. They have further obtained a certificate from Cost Accountant which has endorsed the certification of the Chartered Accountant regarding cost of manufacture plus 10% notional profit. The Certificate was discarded by the lower authorities only on the ground that the c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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