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Issues: (i) whether the value of carry bags supplied with laptops was includible in the assessable value of the computers; and (ii) whether the value of AC-DC static converters supplied with the computers was includible in the assessable value.
Issue (i): whether the value of carry bags supplied with laptops was includible in the assessable value of the computers.
Analysis: The carry bags were separately shown in the invoice and were supplied in the course of trade with laptops for carrying the computers and accessories. They were not treated as part of the computer itself.
Conclusion: The value of the carry bags was not includible in the assessable value of the laptops.
Issue (ii): whether the value of AC-DC static converters supplied with the computers was includible in the assessable value.
Analysis: The converters were found not to be cleared with every computer and the computer was complete without them. They were optional accessories and not integral components of the computer.
Conclusion: The value of the AC-DC static converters was not includible in the assessable value of the computers.
Final Conclusion: The Revenue's challenge failed and the exclusion of the value of both items from the assessable value was upheld.
Ratio Decidendi: Accessories supplied separately in trade, which are not integral to the manufactured product and are not cleared with every unit, are not includible in the assessable value.