Notional interest on customer advances is excluded from assessable value absent evidence it formed part of the price.

Notional interest on advances received from customers for manufacture of machine tools to their specifications was not includible in assessable value. The valuation question was governed by the binding Supreme Court ratio and consistent Tribunal decisions, which treat customer advances as outside the price unless there is evidence that interest formed part of the consideration. No such evidence or distinguishing feature was shown, so the settled valuation principle was applied and the appellant obtained relief.

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Issues: Whether notional interest on advances received from customers for manufacture of machine tools to their specifications was includible in the assessable value.

Analysis: The issue was governed by the binding ratio of the Supreme Court and followed Tribunal decisions on valuation, under which advances received from customers could not be treated as part of the price merely because they were retained for a long period. The finding that interest must have formed part of the price was unsupported by evidence, and no distinguishing feature was shown to depart from the settled ratio.

Conclusion: The notional interest on customer advances was not includible in the assessable value, and the appeal succeeded.

Final Conclusion: The impugned order was set aside and the appellant obtained relief on valuation.

Ratio Decidendi: Notional interest on customer advances is not includible in the assessable value unless there is evidence that such interest formed part of the price or valuation.

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