ALO Law Office- IDT Tax I Arbitration I Litigation
Date: 02.06.2025
CESTAT Chennai Upholds Transaction Value in Solar Equipment Imports by Enfinity Solar
The Customs, Excise & Service Tax Appellate Tribunal (CESTAT), Chennai Bench has dismissed the appeal filed by the Commissioner of Customs, upholding the decision in favour of M/s Enfinity Solar Solutions Pvt. Ltd. The Tribunal found that the Customs Department had no valid legal grounds to load the transaction value of imports made under unrelated-party invoices, despite the alleged related-party concerns.
The final order, pronounced on 29 May 2025, reaffirmed the legal position that valuation under the Customs Act must be based on actual commercial evidence, not assumptions or analogies to income tax transfer pricing methods.
Case Background
- Appellant: Commissioner of Customs, Chennai
- Respondent: M/s Enfinity Solar Solutions Pvt. Ltd.
- Imports Involved: Solar panels, photovoltaic (PV) cables, power inverters, and accessories
- Foreign Entities: Enfinity N.V., Belgium (Parent Co.) & Enfinity Asia Pacific (Trading) Ltd., Hong Kong
This Article has been written by Shri Ravi Shekhar Jha, Advocate Delhi High Court based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com or on his Mobile +91-9999005379.
Source: CESTAT Chennai
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