Valuation principles on freight deduction and software inclusion were applied to uphold the assessee's relief against Revenue's challenge.

A specific 30-day period granted by the Commissioner (Appeals) to produce proof of actual freight payment was not an indefinite extension, so the Revenue's objection failed and the freight deduction was upheld. The assessable value of computers did not include the value of application software where the Commissioner (Appeals) accepted the assessee's claim on the basis of substantial force in the submissions, and Revenue produced no material to rebut that finding. The valuation-related challenge therefore failed in full, leaving the assessee's relief intact.

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Issues: (i) Whether the Commissioner (Appeals) could grant the assessee 30 days to produce proof of actual freight paid for claiming freight deduction in valuation; (ii) Whether the value of application software was includible in the assessable value of computers where the Commissioner (Appeals) accepted the assessee's claim on the basis of substantial force in the submissions.

Issue (i): Whether the Commissioner (Appeals) could grant the assessee 30 days to produce proof of actual freight paid for claiming freight deduction in valuation.

Analysis: The period granted by the Commissioner (Appeals) was a specific period of 30 days and could not be treated as an indefinite extension. The objection raised by Revenue proceeded on an incorrect premise.

Conclusion: The issue was decided against Revenue and in favour of the assessee.

Issue (ii): Whether the value of application software was includible in the assessable value of computers where the Commissioner (Appeals) accepted the assessee's claim on the basis of substantial force in the submissions.

Analysis: The finding of the Commissioner (Appeals) was not shown to be unsupported by record. Revenue did not produce material to rebut the basis on which the claim was accepted, and the challenge failed for want of substantiation.

Conclusion: The issue was decided against Revenue and in favour of the assessee.

Final Conclusion: The Revenue's challenge to the valuation-related findings failed in full, and the dismissal of the appeal left the assessee's relief intact.

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