Assessable value requires clear factual findings before bought-out items can be excluded or included in valuation.

Assessable value could not be determined on the existing record because the nature of the finished goods and the character of the bought-out items were not clearly established. Without clear factual findings, the conclusion on includibility of those items in valuation could not be sustained. The appellate authority was required to examine the material facts, apply its mind to the valuation issue, and record a reasoned decision. The impugned order was therefore set aside and the matter remitted for fresh adjudication in accordance with law, leaving the includibility question open for reconsideration on the evidence.

---

---

Issues: Whether the cost of bought-out items used in the manufacture of the finished goods was liable to be included in the assessable value, and whether the appellate order could be sustained in the absence of clear factual findings.

Analysis: The factual basis necessary to determine the nature of the finished goods and the character of the disputed bought-out items was not clear from the record. In the absence of clarity on these material facts, it was not possible to examine the correctness of the conclusion that such items were not includible in the finished product. The proper course was for the appellate authority to apply its mind to the facts and record a reasoned decision on the issues arising from them.

Conclusion: No final finding was returned on includibility of the bought-out items; the impugned order was set aside and the matter was remitted for decision in accordance with law.

Final Conclusion: The dispute was reopened for fresh adjudication on the factual and valuation issues, and the earlier appellate decision ceased to operate.

Ratio Decidendi: Where material facts necessary for valuation are unclear, a finding on assessable value cannot be sustained without a reasoned factual determination, and the matter must be reconsidered on the record.

---