Notional interest on customer advances is not includible in assessable value absent proof that the advance reduced the goods' price.

Notional interest on customer advances is includible in assessable value only where the Department proves a nexus between the advance and a reduced price for the goods supplied. On the available material, that link was not established, and the assumption that advances ordinarily carry interest was held insufficient. The explanation that the advances were taken to secure orders for specially fabricated goods was accepted, so the notional interest was not includible in the assessable value and the inclusion order could not stand.

---

---

Issues: Whether notional interest on customer advances was liable to be included in the assessable value of the manufactured goods.

Analysis: Inclusion of notional interest depends on proof that the advance reduced the price of the goods supplied. The available material did not show that the advances had such an effect. The Department failed to establish the requisite nexus, and the presumption that an advance ordinarily carries interest was treated as insufficient. The explanation that advances were taken to secure orders for specially fabricated goods was found acceptable.

Conclusion: The notional interest was not includible in the assessable value, and the order confirming such inclusion could not be sustained.

---