Assessable value excludes post-manufacture loading charges when goods are already complete and invoiced separately.

Loading charges incurred after oleum was filled into the assessee's tanks, and separately shown in invoices for loading into customer-arranged tankers, did not form part of the assessable value under section 4 of the Central Excises and Salt Act, 1944. The goods were already manufactured when filling into the assessee's tanks was complete, so later loading expenses were distinct from the wholesale cash price and could not be treated as part of assessable value. Inclusion of those charges would wrongly assume the wholesale market existed at the buyer's premises. The loading charges were therefore not includible, and the addition was unsustainable.

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Issues: Whether loading charges incurred for loading oleum into tankers at the time of delivery formed part of the assessable value under section 4 of the Central Excises and Salt Act, 1944.

Analysis: The loading charges were shown separately in the invoices and related to loading the goods into tankers arranged by the customers or on their behalf. The manufacture of the goods was complete when the goods were filled in the assessee's tanks. Charges incurred thereafter were distinct from the wholesale cash price and could not be treated as part of the assessable value. Their inclusion would incorrectly proceed on the basis that the wholesale market existed at the buyer's premises.

Conclusion: The loading charges were not includible in the assessable value, and the addition made by the Assistant Collector was not sustainable.

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