Customer-supplied optional components excluded from assessable value where they are separate goods and not essential to the excisable product.

Customer-supplied ball valves used only optionally for mounting actuators were held not to form part of the actuators' assessable value. The actuators and ball valves were treated as separate goods with independent market identities, and the factual finding was that actuators were ordinarily cleared without being fitted on ball valves. Because the valves were not an essential component of the excisable product and did not constitute additional consideration for it, their free supply by the customer was outside the valuation base. The demand raised on that footing could not be sustained.

---

---

Issues: Whether the value of ball valves supplied free of cost by the customer and used only in optional cases for mounting actuators was includible in the assessable value of the actuators.

Analysis: The actuators and ball valves were treated as independent goods having separate identities in the market. The factual finding accepted was that actuators were cleared in most cases without being fitted on ball valves, and that mounting of actuators on ball valves was only optional. On that basis, the free supply of ball valves by customers did not constitute an element necessary for determining the assessable value of the actuators, nor did it amount to includible additional consideration.

Conclusion: The value of the customer-supplied ball valves was not includible in the assessable value of the actuators, and the demand on that basis could not be sustained.

Ratio Decidendi: Where a separately identifiable component supplied by the customer is used only optionally and is not an essential part of the excisable product, its value is not includible in the assessable value of that product.

---