Assessable value of factory-cleared goods excludes post-clearance cutting and slitting cost where the statutory note does not apply.

Polyester film cleared from the factory in jumbo rolls was to be valued in the form in which it left the factory, so post-clearance cutting and slitting at the depot was not includible in the assessable value. Chapter Note 10A of Chapter 48 did not apply because it referred to thermal paper, not polyester film. On that basis, the Tribunal treated the depot processing cost as outside valuation, and noted that any separate jurisdiction objection was immaterial to the issue before it. The Revenue's challenge therefore failed, and valuation remained confined to the factory-clearance form of the goods.

---

---

Issues: Whether the cost of cutting and slitting carried out at the depot was includible in the assessable value of polyester film cleared from the factory in jumbo rolls, and whether Chapter Note 10A of Chapter 48 applied to treat such cutting and slitting as manufacture.

Analysis: The goods were cleared from the factory in jumbo roll form and were assessable in the form in which they left the factory. Chapter Note 10A of Chapter 48 was held inapplicable because it referred to thermal paper and not to polyester film. Since the disputed activity was carried out after clearance at the depot, the value attributable to cutting and slitting could not be added to the assessable value. The Tribunal also noted that, even assuming the activity amounted to manufacture, the objection regarding jurisdiction was not material to the appeal before it.

Conclusion: The cost of cutting and slitting was not includible in the assessable value, and the Revenue's appeal failed.

Final Conclusion: The Tribunal affirmed valuation on the basis of the goods as cleared from the factory and rejected inclusion of post-clearance processing cost.

Ratio Decidendi: Where goods are cleared from the factory in a particular form, their assessable value is to be determined on that basis and post-clearance processing cost is not includible unless the statutory provision relied upon squarely applies to the goods in question.

---