Quantity-linked trade discount remains deductible even for depot clearances when offered uniformly to all buyers.

A quantity-based discount granted uniformly to every buyer was treated as a deductible trade discount in computing assessable value. Its availability was not affected by the fact that the goods were cleared to a depot rather than sold directly at the factory gate, because the discount was not contingent on differing purchase conditions and was available across buyers. The cited precedent recognised that quantity-linked free supply can qualify as a deductible discount and that depot clearances do not by themselves defeat such a claim. The discount was therefore allowable and could not be disallowed on those grounds.

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Issues: Whether discount expressed in quantity terms, granted uniformly to every buyer, was deductible from the assessable value notwithstanding that the goods were cleared to the depot and not sold directly at the factory gate.

Analysis: The discount claimed was in substance a quantity discount and not a mere abatement from the normal price. The absence of sales from the factory did not defeat the claim, since the discount was available to every buyer and was not contingent on varying purchase conditions. The cited precedent accepted quantity-linked free supply as a deductible discount and also recognised its availability where goods were sold from a depot rather than the factory.

Conclusion: The discount was allowable and could not be disallowed on the ground that clearances were made to the depot or that the discount was expressed in quantity terms.

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