Notional interest on customer advances was excluded from assessable value absent proof that the advances depressed price or valuation.

Notional interest on advances received from customers was not includible in the assessable value of the final product where the Revenue failed to prove that the advances depressed or reduced the assessable value. Advances taken as a trade practice, without evidence that they caused depreciation in price or valuation, did not justify adding notional interest to the assessable value. The demand was therefore unsustainable.

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Issues: Whether notional interest on advances received from customers was liable to be added to the assessable value of the final product.

Analysis: The Revenue had the burden to establish that the advances resulted in lowering of the assessable value. The record did not contain any finding that the advances had caused depreciation or depression in the assessable value. Advances received as a trade practice, without proof of such effect, did not justify inclusion of notional interest in the assessable value.

Conclusion: Notional interest on customer advances was not includible in the assessable value, and the demand could not be sustained.

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