Related persons and mutual pecuniary interest justified valuation on the buyer's resale price.

Common partners and exclusive sales to the purchasing concern established that the two firms were related persons with mutual direct and indirect pecuniary interest in each other's business. Because that relationship meant the sale price to the buyer was not the proper assessable value, valuation was correctly based on the price realised by the buyer on resale. The assessment order was upheld and the appeal was rejected.

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Issues: Whether the appellants and the purchasing concern were related persons having mutual pecuniary interest, and whether the assessable value was to be based on the price at which the related buyer resold the goods.

Analysis: The two firms had common partners and the goods were sold exclusively to the purchasing concern. On these admitted facts, the relationship between the units showed direct and indirect interest in each other's business, amounting to pecuniary interest. The sale price to the related buyer was therefore not the proper basis for assessment, and the price realised by the related buyer on resale formed the relevant basis for valuation.

Conclusion: The firms were related persons and the buyer's resale price was correctly adopted for assessment.

Final Conclusion: The assessment order was upheld and the appeal was rejected.

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