COMMISSIONER OF CUSTOMS, NEW DELHI vs M/S. PRODELIN INDIA (P) LTD.

The Supreme Court upheld the decision of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) which ruled that the relationship between M/s Prodelin India (P) Ltd. and M/s Prodelin Corporation U.S.A. did not justify an increase in the invoice value of imported goods under the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988. The Court clarified that while the companies were related, this alone did not warrant an adjustment to the sale price, as the sourcing assistance was relevant only when dealing with third parties. The appeal by the Commissioner of Customs was dismissed, affirming the CESTAT's order.