Retail price abatement valuation must be supported by comparable evidence; matter remanded for fresh adjudication.

Abatement from retail price under Rule 6(a) was to be assessed by reference to the margin between assessable value and the retail price of comparable goods, with averaging contemplated where margins vary materially. The assessee's claim for a higher abatement based on comparable marketing pattern was not supported by sufficient evidence before the original authority. As the existing record was inadequate for a final determination on the valuation issue, the matter was remanded for fresh adjudication, with permission to file additional evidence and written submissions. No final view was expressed on the merits of the valuation claim.

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Issues: Whether the valuation dispute concerning abatement from the retail price should be remanded for fresh consideration.

Analysis: The deduction from retail price under Rule 6(a) was to be determined with reference to the margin between the assessable value and the retail price of comparable goods, and the Board's guidance contemplated averaging where the margin varied considerably. The assessee had sought 28% abatement on the footing that its marketing pattern was similar to that of another manufacturer, but relevant supporting details had not been produced before the original authority. In these circumstances, the existing findings were not treated as sufficient for a final decision on merits, and the matter was sent back for reconsideration after allowing the assessee to place evidence and written submissions.

Conclusion: The matter was remanded to the original authority for fresh adjudication; no final view was expressed on the merits of the valuation claim.

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