Intellectual Property Rights in connection with the manufacture and sale of specified products in India by paying royalty @ 3.7% and 4% of net sale volume of the finished goods manufactured and sold to customers. In 2007, Assistant Commissioner of Customs, Special Valuation Branch (SVB) Mumbai passed an ex parte order rejecting the declared invoice value and for loading of declared invoice price by 100% under the provisions of Rule 8 read with Rule 9 of the Customs Valuation Rules, 2007. Thereafter, when the office of the Appellant was shifted to Bangalore on 02.06.2007, the Appellant stopped import from Chem Trend, Singapore and started to import from Chem Trend, USA. The Appellant filed documents before the SVB Chennai which was transferred to SVB Bangalore. Appellant had submitted various documents pertaining to operation and valuation of goods. Appellant had also produced import prices, comparing the import price with transfer price list by way of comparison and submitted that the goods are supplied across the global to the other related parties at the same price as mentioned in the Appellant’s price list. However, the Assistant Commissioner, SVB Bangalore passed an order dated 02.02.2016 ordering loading of 100% value on the declared price along with addition of payment made towards royalty under Rule 10(1)(c) of the Customs Valuation Rules, 2007. Aggrieved by this order, an Appeal was filed before the Commissioner (Appeals) and the Commissioner (Appeals) partially allowed the appeal by setting aside the loading of import value by 100% and additional royalty of the assessable value. However,
