Assessable value of bought-out accessories excluded where no proof showed their cost was omitted from the declared machine price.

The value of bought-out items supplied with manufactured goods was not includible in assessable value where the record did not clearly distinguish manufactured goods from purchased items and no material showed that the cost of additional accessories had been omitted from the declared machine value. A claimed Board circular was not produced and, in any event, could not override the law. Items treated as accessories or components already reflected in the price list were not separately added merely because some supply was optional, since optional supply did not make them standard equipment. The departmental appeal therefore failed.

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Issues: Whether the value of bought out items supplied along with the manufactured goods was includible in the assessable value.

Analysis: The items in question were not shown to be manufactured by the assessee, and the record did not identify with certainty which goods were manufactured and which were bought out. The claimed Board circular was not produced, and in any event such a circular could not override the law. The goods covered by the relevant price list were treated as accessories or components already reflected in the declared value of the machine in some cases, and no material established that additional accessories were supplied without their cost being included. The plea that certain items were optional also did not support inclusion in the assessable value, since optional supply did not make them part of standard equipment.

Conclusion: The value of the bought out items was not required to be included in the assessable value, and the appeal by the department failed.

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