Deductibility of post-manufacturing charges upheld where interest on receivables was contractually known in advance.

Interest on receivables and collection charges were treated as post-manufacturing expenses deductible from the assessable value of packet tea, because the agreement had already stipulated interest on outstanding sales proceeds in advance. The liability to pay interest was therefore known beforehand, and deduction could not be refused on the ground that the expenditure was not pre-known. The claim was stated to be covered by the Supreme Court authority relied on by the appellant, so the denial of relief was incorrect and the deduction was allowable.

---

---

Issues: Whether interest on receivables and collection charges were deductible from the assessable value of the packet tea, and whether such deduction could be denied on the ground that the expenditure was not known beforehand.

Analysis: The amounts claimed were in the nature of post-manufacturing expenses and, on the facts, the agreement itself showed that interest on outstanding sales proceeds was contractually stipulated in advance. Since the liability to pay interest on receivables was known beforehand, the reason given for denying deduction was unsustainable. The claim was covered by the governing Supreme Court decision relied upon by the appellant.

Conclusion: The deduction was allowable and the denial of relief was incorrect.

---