Wholesale cash price at importation governs customs valuation; notional deductions for assembling, cartage, and overheads were disallowed.

Imported motor cars were valued by reference to the wholesale cash price at the time and place of importation under Section 30(a) of the Sea Customs Act, 1878. The importer-dealer sale was treated as complete only when the goods arrived in Bombay, the dealers were notified of the price, cash payment was made, and delivery followed within a reasonable time; on that basis, the statutory requirement of a sale at importation was satisfied. The Court also held that the price was a wholesale cash price, and that net discount did not change that character. It further rejected deductions for assembling, cartage, overheads, and similar charges, holding that the statute did not permit reconstruction of a notional value by mathematical reduction.

---

---

Issues: Whether the assessable value of imported motor cars was the wholesale cash price at the time and place of importation under Section 30(a) of the Sea Customs Act, 1878, and whether deductions for assembling, cartage, overheads, and similar charges were permissible.

Analysis: The sale between the importer and its dealers was treated as complete only when the goods arrived in Bombay, the dealers were notified of the price, payment was made in cash, and delivery followed within a reasonable time. On that basis, the transaction answered the statutory requirement of a sale at the time and place of importation. The price charged was held to be a wholesale cash price, as distinct from the retail price, and the existence of a net discount did not alter that character. The Court further held that it was not permissible to dissect the actual sale price and deduct estimated elements said to represent assembly, cartage, overheads, or other services, because the statute required the Court to identify the wholesale cash price of the goods as sold, not to reconstruct a notional value by mathematical reduction.

Conclusion: The assessment under Section 30(a) was correct, and the importer failed to show that the customs valuation basis was unlawful.

---