Assessable value of plastic tubes excludes separately manufactured customer-supplied caps, subject to fresh factual determination.

The assessable value of plastic tubes does not include the value of plastic caps where the caps are separately manufactured and not produced in the same factory as the tubes. The settled valuation principle applied was that such caps are not an integral part of the tubes for assessable value purposes. On the record, however, there was no clear finding whether the caps for the disputed clearances were supplied by customers free of cost and fitted in the appellant's factory. Because the valuation outcome depended on that factual determination, the matter was remitted for a fresh finding by the Commissioner.

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Issues: Whether the value of plastic caps fitted to plastic tubes is includible in the assessable value of the tubes when the caps are separately manufactured or supplied by customers free of cost.

Analysis: The settled view applied was that where caps are manufactured separately and not in the same factory as the tubes, they do not form an integral part of the tubes for valuation purposes. On the facts before the Court, the record did not contain a clear finding whether the caps for the disputed clearances were supplied by customers free of cost and fitted to the tubes in the appellant's factory. Since the assessable value depends on that factual determination, a fresh finding was necessary.

Conclusion: The value of customer-supplied caps is not includible in the assessable value of the tubes, but the matter required fresh factual determination and was remitted to the Commissioner.

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