Notional interest on advances is excluded from assessable value absent proof of price depression or measurable benefit.

Notional interest on advances is includible in assessable value only where there is proof that the advances depressed the sale price of the final product or gave the assessee a measurable benefit. In the absence of material establishing such nexus, the notional interest cannot be added to the assessable value. The lower appellate view applying the settled position remained undisturbed because no contrary material was produced to show that the principle was inapplicable.

---

---

Issues: Whether notional interest accrued on advances received by the assessee was liable to be included in the assessable value of the final product.

Analysis: The inclusion of notional interest on advances depends on proof that the advances depressed the sale price of the final product or conferred a measurable benefit on the assessee. In the absence of material showing such nexus, the claimed interest cannot form part of assessable value. The settled position relied upon by the lower appellate authority was not shown to be inapplicable, and no contrary material was produced to disturb that finding.

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

---