Assessable value exclusion for bought-out Circlips and Rings supplied with Pistons and G. Pins was upheld.

The assessable value of manufactured Pistons and G. Pins did not include the value of separately bought-out Circlips and Rings supplied with them, because those items were not shown to be parts of the manufactured goods themselves and were only required for assembly in the engine. The Revenue's reliance on a heading covering parts suitable for use with the relevant engines was rejected, as it did not cover an assembly arrangement. An earlier decision on identical facts was treated as governing the controversy, while the precedent concerning bought-out items supplied as part of excisable goods was found inapplicable. The assessee's position was upheld.

---

---

Issues: Whether the value of bought-out Circlips and Rings supplied along with Pistons and G. Pins was includible in the assessable value of the manufactured goods.

Analysis: The heading relied on by the Revenue covered parts suitable for use with the relevant engines, and not an assembly. The bought-out Circlips and Rings were separate items, not shown to be parts of the manufactured Pistons and G. Pins, and were only required for assembling the piston in the engine. The earlier decision on identical facts was held to govern the controversy, while the relied-upon precedent dealing with bought-out items supplied as part of the excisable goods was found inapplicable.

Conclusion: The value of the bought-out Circlips and Rings was not includible in the assessable value of the Pistons and G. Pins, and the assessee's stand was upheld.

---