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TMI Blog2015 (12) TMI 1402X X X X Extracts X X X X X X X X Extracts X X X X ..... nable (i) mutuality of interest, (ii) price is lower to the normal price and (iii) buyer and seller are related person - Held that:- Tribunal has arrived at the aforesaid findings by giving cogent reasons on the basis of evidence that was produced by the respondent(s)/assessee(s). - these are pure findings of fact arrived at by the Tribunal. In fact, in the appeal filed by the Department it is no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Proprietary Medicines ( P or P medicines) manufactured by it and supplied to Dr. Reddy Laboratories (DRL) were undervalued and, therefore, lesser excise duty was paid. It was alleged that the parties were related persons and because of these reasons the price which was agreed upon did not reflect true transaction as well. Notice was also issued to DRL proposing fine for the aforesaid arrangement m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rangement was entered into between SMIPL and DRL under which SMIPL agreed to manufacture the aforesaid medicines, albeit under the trade name/trade mark of DRL. In this manner, SMIPL undertook the job work on behalf of the DRL. These were the reasons for issuance of show cause notices in which it was inter alia alleged that the shares of ARL were purchased by DRL at a very high rates and in this m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s produced on record has negated all the aforesaid factors which were taken into account by the Commissioner and has arrived at detailed findings of fact stating that the respondent(s)/assessee(s) have been able to satisfactorily explain each and every allegation. The order of the Tribunal which runs into 108 pages has been gone into by us and we find that the Tribunal has arrived at the aforesaid ..... X X X X Extracts X X X X X X X X Extracts X X X X
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