CAS-4 valuation for captively consumed goods requires fresh quantification, with linked demand and limitation issues reconsidered.

Pending assessments of captively consumed goods are to be reworked under the CAS-4 valuation formula once it becomes applicable, and the jurisdictional authority must complete fresh quantification on that basis. Where the underlying valuation exercise is unsettled, related demand and limitation questions may also require reconsideration, especially if the adjudication proceeded on an assumed provisional assessment or on a footing different from the show-cause notice. The matter therefore calls for fresh adjudication after re-evaluation of the valuation basis and the connected demand issues.

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Issues: (i) whether the assessable value of captively consumed goods had to be re-determined in accordance with the CAS-4 formula and the valuation dispute remanded for fresh quantification; (ii) whether the demand for the later period could be sustained on the premise of provisional assessment and absence of limitation, warranting reconsideration on remand.

Issue (i): whether the assessable value of captively consumed goods had to be re-determined in accordance with the CAS-4 formula and the valuation dispute remanded for fresh quantification.

Analysis: The goods had earlier been assessed on a basis not governed by CAS-4, but once the formula came into force the Board clarified that pending assessments of captively consumed goods were to be completed under that formula. The assessments in both matters therefore required redoing on the basis of CAS-4, and the valuation dispute could not be finally resolved without fresh quantification by the jurisdictional authority.

Conclusion: The valuation issue was remanded for reassessment under the CAS-4 formula.

Issue (ii): whether the demand for the later period could be sustained on the premise of provisional assessment and absence of limitation, warranting reconsideration on remand.

Analysis: The record did not show provisional assessment, yet the adjudicating authority had proceeded on that basis and had also dealt with limitation on a footing different from the show-cause notice. Since the same valuation exercise under CAS-4 governed the period in dispute, the correctness of the demand and the limitation finding required a fresh decision after reconsideration of all issues.

Conclusion: The assessee's challenge was remanded for fresh adjudication on all issues.

Final Conclusion: Both matters were returned to the adjudicating authority for fresh determination, with valuation to be reworked under CAS-4 and the connected demand-related questions reconsidered after hearing the parties.

Ratio Decidendi: Pending assessments of captively consumed goods must be reworked under CAS-4 when that formula becomes applicable, and where the foundational valuation exercise is unsettled, connected demand and limitation questions may be remanded for fresh adjudication.

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