Assessable value for galvanised goods excludes job-worker galvanization cost where the process is outsourced and in-house precedent differs.

Cost of galvanization was treated as not includible in the assessable value of M.S. black bolts and ungalvanized nuts where galvanization was carried out by an independent job worker. The analysis distinguished in-house galvanization from job-work galvanization and held that the Supreme Court ruling relied on by the Revenue, which concerned galvanization undertaken by the assessee in its own factory, did not apply to these facts. On that basis, inclusion of galvanization cost was unwarranted and the valuation order was affirmed.

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Issues: Whether the cost of galvanization was liable to be included in the assessable value of M.S. black bolts and ungalvanized nuts when galvanization was carried out by an independent job worker.

Analysis: The valuation adopted by the lower authority was upheld on the footing that galvanization done through a job worker stood on a different footing from in-house galvanization. The reliance placed by the Revenue on the Supreme Court decision concerning galvanization performed by the assessee in its own factory was held to be inapplicable to the present facts.

Conclusion: The inclusion of the cost of galvanization was not warranted on the facts of this case, and the impugned order was affirmed.

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