TMI Blog2018 (9) TMI 1887X X X X Extracts X X X X X X X X Extracts X X X X ..... f the goods are proprietorship of brothers. However, no investigation was carried out to bring evidence on record, there is no mutuality such as flowback of funds, mutual interest in the business of each other, etc. Therefore, merely because the appellant s supplier and buyer are proprietorship of brothers, this alone cannot be the reason for holding that both are related persons. Moreover, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r the purpose of valuation. Accordingly, the duty is chargeable in terms of Rule 8, i.e. 110% of the cost of manufacture. 2. Shri Amal Dave, Ld. Counsel appearing on behalf of the appellant submits that except the relationship of brothers, there is no evidence on record that there is mutuality of interest among both the proprietor-ship concerns. Therefore, they are not related persons in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ties have demanded the duty on the ground that the appellant supplier and buyers of the goods are proprietorship of brothers. However, o investigation was carried out to bring evidence on record, there is no mutuality such as flowback of funds, mutual interest in the business of each other, etc. Therefore, merely because the appellant s supplier and buyer are proprietorship of brothers, this alone ..... X X X X Extracts X X X X X X X X Extracts X X X X
|