Notional interest on customer advances not added to assessable value absent proof of price depression or identifiable benefit.

Notional interest on advances from customers was not includible in the assessable value of manufactured goods where the advances were taken in the ordinary course of producing customer-specific goods. The record did not establish that the advances had depressed the price or that the assessee derived any identifiable benefit from them warranting loading of value. In the absence of evidence showing the extent of such benefit, notional interest could not be added to the assessable value, and the issue was decided in favour of the assessee.

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Issues: Whether notional interest on advances taken from customers was includible in the assessable value of the manufactured goods.

Analysis: The advances were collected from customers in the ordinary course of the manufacture of customer-specific goods. The material on record did not show that the price was depressed because of the advances or that any identifiable benefit from the advances had been obtained by the assessee so as to warrant loading of the price. In the absence of evidence establishing the extent of any such benefit, notional interest could not be added to the assessable value.

Conclusion: Notional interest on advances was not includible in the assessable value and the issue was decided in favour of the assessee.

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