Job-work valuation under Ujagar Prints cannot be replaced merely because another unit of the same assessee shows a higher value.

Job-work clearances must be valued under the Ujagar Prints principle by adding raw material cost, packing charges and job-work charges, including the job worker's margin of profit. The Department cannot reject that valuation merely because identical goods manufactured in another unit of the same assessee attract a higher assessable value. A separate contention on brand name value was not entertained because it was not raised in the show cause notice. The note reaffirms that job-work valuation follows the established Ujagar Prints basis unless the notice itself puts the relevant valuation issue in dispute.

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Issues: Whether the assessable value of goods manufactured on job work basis had to be determined in accordance with the Ujagar Prints principle, and whether the Department could reject that valuation merely because the same product manufactured in another unit of the assessee fetched a higher assessable value.

Analysis: The goods manufactured in the job-work unit were valued by adding the raw material cost, packing charges and job-work charges, which included the assessee's margin of profit. The Department sought to discard that method on the ground that the assessable value of identical goods manufactured in the assessee's own unit was higher. The Tribunal held that where the assessee follows the Ujagar Prints basis for job-work valuation, the Department cannot substitute a different value merely because a separate manufacturing unit of the same assessee shows a higher assessable value. A contention regarding inclusion of brand name value was also not entertained as it had not been raised in the show cause notice.

Conclusion: The assessable value for the job-work clearances had to be determined under the Ujagar Prints principle, and the Department was not justified in rejecting that valuation on the basis of the higher value of the same goods manufactured in the assessee's other unit.

Ratio Decidendi: In job-work valuation, the Department cannot depart from the Ujagar Prints method merely because identical goods manufactured elsewhere by the same assessee are assessed at a higher value.

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