Assessable value of Bus Ducts cannot include bought-out site erection items used in plant installation.

Value of bought-out items purchased from the market and used directly at site for erection and installation of plant machinery cannot be included in the assessable value of Bus Ducts manufactured in the factory. The items in question, including control panels, surge protection devices and current transformers, were not manufactured by the assessee and were only used in site erection. On the stated principle that such items do not form part of the goods manufactured in the factory, the assessable value could not be enhanced and the duty demand was unsustainable.

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Issues: Whether the value of bought-out items purchased from the market and used for erection and installation of the plant at site could be included in the assessable value of the Bus Ducts manufactured in the factory.

Analysis: The dispute concerned items such as control panels, surge protection devices and current transformers which were not manufactured by the assessee, were purchased from the market, taken directly to the installation site and used in erecting the plant. The prior decisions relied upon held that the value of such bought-out items used for erection of plant and machinery at site does not form part of the goods manufactured in the factory. On that basis, the assessable value of the Bus Ducts could not be enhanced by including those items.

Conclusion: The inclusion of the value of the bought-out items was not justified and the duty demand was unsustainable.

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