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Issues: Whether the assessable value of goods manufactured by a job worker was to be determined on the basis of the cost of manufacture, and whether the matter required verification of cost figures and fresh determination of duty.
Analysis: The dispute concerned recovery of alleged short-levied duty on goods manufactured by a job worker. The Tribunal accepted that, in such a case, the correct assessable value had to be based on the cost of manufacture. It further directed that the appellant furnish evidence of cost of manufacture to the Assistant Commissioner, who would examine its acceptability, determine the correct assessable value, and pass appropriate orders on any duty short-levied.
Conclusion: The appellant succeeded on the principle that valuation had to be made on the basis of cost of manufacture, but the matter was remitted for verification and fresh quantification of duty.
Final Conclusion: The assessment method proposed by the appellant was accepted in principle, and the dispute was sent back for factual verification and consequential determination.
Ratio Decidendi: Where duty is sought to be recovered as short-levied on goods manufactured by a job worker, the assessable value must be determined on the cost of manufacture, subject to verification of the underlying cost figures.