Outside plating charges not added to excise value where watch cases remained marketable and valuation already included relevant costs.

Ion plating and gold plating carried out at a job worker's premises were treated as non-manufacturing finishing processes because the watch cases remained marketable without the plating. The Tribunal also relied on the primary manufacturer's certificate indicating that the final watch valuation already included the relevant input and plating costs, so no revenue loss arose. Applying valuation principles on outside processing charges, it held that such plating charges were not to be added to the assessable value of the watch cases.

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Issues: Whether the value of ion plating and gold plating undertaken at a job worker's premises was includible in the assessable value of watch cases cleared by the assessee, and whether the process amounted to manufacture requiring addition of such charges for excise valuation.

Analysis: The Tribunal accepted the finding that ion plating and gold plating done outside the assessee's factory did not amount to manufacture of a new commercial product, since the watch cases remained marketable even without the plating process. It also relied on the certificate from the primary manufacturer showing that the assessable value of the final watches already included the relevant input and plating costs, indicating no revenue loss. Applying the principles governing valuation and exclusion of outside processing costs, the Tribunal held that the plating charges were not required to be added to the assessable value of the watch cases.

Conclusion: The addition of ion plating and gold plating charges to the assessable value was not warranted, and the assessee's challenge failed.

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