Assessable value re-adjudication requires consideration of prior record and documentary proof before fresh valuation decision.

Assessable value on re-adjudication had to be determined by considering the material and submissions already recorded by the Tribunal, including the disputed container rental charges and related proof. Although the appellants retained the burden to produce documentary evidence for advertisement charges and rental receipts, the adjudicating authority could not ignore the earlier record. Because that material had not been properly considered, fresh adjudication was required. The matter was therefore remanded again to the Commissioner for re-adjudication after the appellants produced the necessary proof and were given a reasonable opportunity of hearing.

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Issues: Whether the assessable value had been correctly determined on re-adjudication, particularly as to the inclusion of rental charges for containers, and whether the matter required fresh adjudication.

Analysis: The earlier remand had proceeded on the appellants' submissions regarding advertisement charges and rental receipts. Although the burden remained on the appellants to produce documentary proof, the adjudicating authority was required to consider the material and submissions already recorded by the Tribunal. In the absence of such consideration, a fresh adjudication became necessary.

Conclusion: The matter was remanded again to the Commissioner for re-adjudication after the appellants produced the necessary proof and were given a reasonable opportunity of hearing.

Final Conclusion: The assessment on the disputed valuation issue was not finally affirmed or set aside, and the controversy was reopened for fresh decision by the Commissioner.

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