Invisible-loss allowance for semi-finished gold jewellery was denied where no notification covered intermediate manufacturing loss.

An additional invisible-loss allowance for semi-finished gold jewellery during manufacture was not recognised, because the 9% allowance under Notification No. 177/94 applied only to finished gold jewellery and no notification or circular was shown to extend similar relief to intermediate manufacturing stages. The text also notes that the assessee admitted the shortage and paid duty, and the later challenge to the shortage was treated as an afterthought. The departmental order was sustained, and the claim for further allowance rejected.

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Issues: Whether any allowance could be granted for invisible loss occurring during the manufacture of semi-finished gold jewellery, beyond the 9% invisible loss already recognised for finished gold jewellery under Notification No. 177/94 dated 21-10-94.

Analysis: The only controversy was the claimed entitlement to a larger allowance for invisible loss at intermediate stages of manufacture. The Tribunal noted that the 9% allowance had been granted on the basis of the notification applicable to finished gold jewellery and that no notification or circular was shown to permit allowance of invisible loss during the manufacturing process of gold jewellery. The appellants had also admitted the shortage and paid the duty, and the subsequent challenge to the shortage was treated as an afterthought.

Conclusion: The claim for additional invisible-loss allowance was rejected and the departmental order was sustained.

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