Normal packing cost is includible in excise assessable value when goods are cleared in wooden crates as standard delivery packing.

The cost of wooden crates used to pack pressure cookers at the time of removal was includible in assessable value for excise purposes because the crates constituted the normal packing at clearance. The facts showed that most clearances during the relevant period were made in wooden crates, and the packing was not established as special secondary packing ordered by customers. Applying the valuation principle for excisable goods, the cost of normal packing formed part of assessable value, so the departmental valuation was sustained and the challenge failed.

---

---

Issues: Whether the cost of wooden crates used for packing pressure cookers at the time of clearance was includible in the assessable value for excise purposes.

Analysis: The decisive test was whether the crates constituted the normal packing at the time of removal from the factory. The appellants' own figures showed that the overwhelming majority of the clearances during the relevant period were made in wooden crates. On the facts, the crates were not shown to be special secondary packing ordered by customers. Applying the governing principle on valuation of excisable goods, the cost of such normal secondary packing formed part of the assessable value.

Conclusion: The cost of wooden crates was rightly included in the assessable value, and the challenge to the demand failed.

Final Conclusion: The appeal was rejected, and the valuation adopted by the departmental authorities was sustained.

Ratio Decidendi: The cost of packing is includible in the assessable value where the packing is the normal mode of delivery at removal and is not shown to be special secondary packing ordered by customers.

---