Pre-removal discount rule governs valuation, so post-clearance negotiated discounts were rejected as impermissible deductions.

Discounts deductible from assessable value must be known and understood before clearance of goods; discounts negotiated only after removal, including by telephone or across the counter, do not qualify as permissible pre-removal discounts. On that basis, a discount exceeding 10% was held not allowable for valuation purposes, and the Revenue's challenge succeeded.

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Issues: Whether discounts negotiated after removal of goods and not known to buyers prior to removal were permissible for valuation purposes, and whether discount in excess of 10% could be allowed.

Analysis: Discounts that are to be deducted from the assessable value must be known and understood before clearance of the goods. Discounts negotiated over the telephone or across the counter after removal do not satisfy that requirement and cannot be treated as permissible pre-removal discounts.

Conclusion: The discount in excess of 10% was not permissible and the Revenue's challenge succeeded.

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