Notional interest on buyer advances excluded from assessable value absent proof of additional consideration or valuation nexus.

Notional interest on advances received from buyers was held not includible in assessable value because the department had not shown that the deposits were additional consideration or that they depressed the assessable value. The order required a specific nexus between the buyer advances and the valuation of goods before any notional interest could be added, and it relied on later judicial guidance and the Board's circular to reject the demand.

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Issues: Whether notional interest on advances received from buyers was includible in the assessable value of the goods.

Analysis: The demand was founded on the premise that buyer advances yielded a monetary benefit warranting addition of notional interest to assessable value. The order noted that the show cause notice did not allege that the deposits constituted an additional consideration or that they had depressed the assessable value. It further relied on later judicial guidance and the Board's circular, which required the department to establish a specific nexus between the deposit and the assessable value before such notional interest could be added.

Conclusion: Notional interest on the advances was not includible in the assessable value, and the demand could not be sustained.

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