Post-removal charges for delayed payment treated as interest on receivables and excluded from assessable value.

Amounts collected as post-removal expenses for delayed payment were treated as interest-related costs for extending credit, not part of the assessable value. The buyer communications, purchase orders, billing pattern, and refund practice where payment was made before expiry of the credit period supported this characterisation, and the accounting description used for the receipts was held to be irrelevant. Additional interest for further delay was separately recovered by debit notes, reinforcing that the amount was compensation for receivables rather than a pricing element. The amount was therefore not liable to be added to the assessable value.

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Issues: Whether the amount collected as post-removal expenses for delayed payment was includible in the assessable value.

Analysis: The communications sent to buyers, the purchase orders, and the billing pattern showed that the amount was understood as interest-related cost for extending credit. The fact that the amount was reflected under accounting heads other than "interest" was held to be irrelevant. The record also showed that the amount was refunded where payment was made before expiry of the credit period, and no contrary transaction was produced by the Revenue. Reliance was placed on the departmental circular and on the evidence that additional interest for extended delay was separately recovered by debit notes.

Conclusion: The amount collected as PRE was held to be interest on receivables and was not liable to be added to the assessable value.

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