Assessable value excludes notional interest on buyer deposits and treats distributor margin as non-deductible discount.

Interest calculated at the prevailing bank rate on buyers' deposits is not includible in assessable value where those deposits are already reflected in the value adopted by the assessee. The text also explains that an amount described as discount is deductible only if it is a true reduction from the sale price; where the material shows it functions as a distributor margin under the distributorship terms, no further deduction is available. The operative point is that assessable value is determined by the real commercial structure of the transaction, not by notional additions or labels that do not reflect the actual price mechanism.

---

---

Issues: (i) whether interest calculated at the prevailing bank rate on buyers' deposits was includible in the assessable value of the goods; (ii) whether the amounts described as discount or distributor margin were deductible from the sale price.

Issue (i): whether interest calculated at the prevailing bank rate on buyers' deposits was includible in the assessable value of the goods.

Analysis: The deposits taken from buyers were already reflected in the value adopted by the assessee. The claim for further inclusion of interest at the bank rate was not accepted, following the Tribunal's earlier view on the same issue.

Conclusion: The issue was decided in favour of the assessee, and the additional interest was held not includible.

Issue (ii): whether the amounts described as discount or distributor margin were deductible from the sale price.

Analysis: The material showed that the so-called discount operated as a distributor margin and not as a true deduction from the sale price. The price list and distributorship terms indicated that the sale price itself corresponded to the assessable value, leaving no basis for a further deduction.

Conclusion: The issue was decided against the Revenue, and the departmental demand was rejected.

Final Conclusion: The assessee succeeded on the interest-inclusion issue, while the Revenue failed on the alleged discount deduction issue, resulting in disposal of the connected appeals in opposite directions.

Ratio Decidendi: Amounts that function only as distributor margin, and not as true deductions from the sale price, cannot be treated as deductible discount for assessment purposes; likewise, a further notional inclusion of interest is impermissible where the value already reflects the relevant deposit component.

---