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2. The brief facts of the case are that M/s.Google India Pvt. Ltd., Bangalore (Indian Company/appellant herein) is registered with Software Technology Park of India (STPI, for short) for development of software and Information Technology Enabled Software and export thereof. They are availing full exemption from payment of Customs duty under Notification No.52/2003 dt. 31.3.2003 on imports i.e. Desktops, Laptops etc. from various suppliers and other equipments from M/s.Google Inc., USA. Since Google Inc. (Supplier) holds one share (0.001%) in the appellant-company and M/s.Google International LLC holds 99.99% of shares in the Indian company i.e. appellant. and the Board of Directors of the appellant-company are also represented by employees of Google Inc., USA, the Customs Special Valuation Branch, Chennai has taken up the issue and registered a case for determining the relationship and valuation of the imports made from their related supplier. After issuing detailed questionnaire to the appellants, and upon receipt of replies and documents and also after personal hearing, the Deputy Commissioner (Customs), Special Valuation Branch, Chennai vide Order-in-Original No.13413/2010 dt. 3.11.2010 held that both the appellant and M/s.Google Inc., USA are related in terms of Rule 2 (2) of Customs Valuation (Determination of Value of Imported Goods) Rules 2007, rejected the declared invoice price and ordered for loading price by 20% and 41.125% if the invoice is CIF or FOB basis respectively. Aggrieved by this SVB order passed by the adjudicating authority, the appellant preferred appeal and the Commissioner (Appeals) vide impugned Order dt. 28.6.2012 upheld the Lower Authority's order loading of invoice value and rejected their appeal. Hence the present appeal.