submits that such companies ought not to be taken as
comparable.
Additional filters are unwarranted in the comparability analysis
8. On the facts ... further erred in applying additional filter of rejecting
companies with less than 75 percent earnings from exports, which is
unwarranted in the comparability analysis
inputs at B 59 for
manufacture of hand primers and fuel filters but since these
were not used in the manufacture of finished goods ... slips, where it is used for manufacture of hand primers and
fuel filters, later cleared on payment of duty. Further, it is
alleged that they
find that there is no dispute as to the fact
that the filters carried the brand names of reputed
parties such Komatsu, Deutz, Volvo, etc., along ... importer to
sell these filters to buyers who want to replace these
filters with the original branded filters. Hence, we find
that the value
Chawla, SSC with
Ms. Pratishtha Chaudhary &
Ms. Nivedita, Advs
versus
MAHLE FILTERS SYSTEMS (INDIA) LTD
.....Respondent
Through: Mr. Neeraj Jain, Mr. Aniket D.
Agrawal ... Mahle Filter
System (India) Ltd. with M/s Purolator India Ltd. and then
changing the name of the company to M/s Mahle Filters Systems
guarantors of the
Petitioners' financial transactions with foreign exporters. On this issue as
well, the Court finds no merit in the contentions advanced ... these guidelines aim to prevent
cartelization and artificial inflation of prices by filtering out non-genuine
importers. This reasoning directly applies to the present matter
restrained from manufacturing, offering for
sale, selling, displaying, advertising, marketing, using, exporting, printing,
whether directly or indirectly, dealing in cigarettes under the marks " GOLD ... FALCON " "GOLD FLICKER " "GOOD
FILTER " and "GOLD POWDER "and/or
any marks/packaging that are nearly identical/ similar
petitioners submits that
after long pending litigation, it has been filtered that grounds
Patna High Court CWJC ... Counsel for the State that none of the
Officials of Bihar State Export Corporation has been adjusted in
the department of Industry, Government of Bihar
finished goods for resale TNMM OP/OR 23,581,287,735
2 Export of slow moving goods TNMM OP/OR 93,348,663
3 Payment ... considered the transfer pricing study and filters adopted by the
assessee for selection of comparables for software development segment and it
has selected 19 comparables
alleged brand building services and attributing 1%
on the Appellant's export sales as well, without appreciating the
fact that the Appellant ... conjectures and surmises and further erred by
not providing the search process, filters applied, qualitative and
quantitative analysis performed for selection of the comparables
finished goods for resale TNMM OP/OR 23,581,287,735
2 Export of slow moving goods TNMM OP/OR 93,348,663
3 Payment ... considered the transfer pricing study and filters adopted by the
assessee for selection of comparables for software development segment and it
has selected 19 comparables
