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Issues: (i) Whether interest on receivables was deductible while determining the assessable value for excise duty; (ii) whether distributors' discount could be extended to non-distributors.
Issue (i): Whether interest on receivables was deductible while determining the assessable value for excise duty.
Analysis: The claim for deduction of interest on receivables had already been negatived in the assessee's own case, and the same reasoning was followed. On that basis, the amount could not be excluded from the assessable value.
Conclusion: Deduction of interest on receivables was not admissible, and the issue was decided against the assessee.
Issue (ii): Whether distributors' discount could be extended to non-distributors.
Analysis: After the amendment to Section 4 of the Central Excise Act, 1944, each sale price became the relevant normal price for assessment. As the discount was not disclosed to the Department during the relevant period, its extension to non-distributors was contrary to law.
Conclusion: Distributors' discount could not be extended to non-distributors, and the issue was decided against the assessee.
Final Conclusion: The impugned order was set aside and the Revenue's challenge succeeded on both issues.
Ratio Decidendi: For excise valuation, interest on receivables is not deductible from assessable value, and an undisclosed distributors' discount cannot be extended to non-distributors after the valuation regime under Section 4 treats each sale price as the normal price.