Post-clearance shrinkage in PVC goods is not an excise deduction and cannot be treated as quantity or trade discount.

Post-clearance shrinkage in PVC sheeting and films is not allowable as an excise deduction where the goods were cleared in their physical form and the reduction occurred only after clearance. The distinction is that shrinkage occurring before clearance may be relevant on the cited precedent, but post-clearance shrinkage does not alter the dutiable quantity. Nor can such shrinkage be treated as a quantity discount, because that concept applies where a larger quantity is ordered, or as a trade or cash discount. The claimed allowance was therefore not admissible.

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Issues: Whether shrinkage occurring after clearance of PVC sheeting and films could be allowed as a deduction for excise duty purposes, or treated as a quantity discount or trade discount.

Analysis: The product was cleared in its physical form and the alleged shrinkage occurred only after clearance. The reliance on the precedent concerning shrinkage was misplaced because, in that case, the shrinkage had already taken place before clearance. A quantity discount applies where a larger quantity is ordered, not where a larger quantity is cleared but duty is paid on a smaller quantity. Trade discount or cash discount principles do not apply to post-clearance shrinkage in length or number of pieces.

Conclusion: The post-clearance shrinkage was not deductible and could not be equated with quantity discount or trade discount. The assessee was not entitled to the claimed allowance.

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