Valuation based on declared charges required factual verification, so the matter was remanded for fresh adjudication.

Valuation of yarn depended on factual verification of whether octroi, transport, loading and unloading charges, manufacturing expenses and wastage were separately declared in the relevant show-cause notices and supporting records. As the annexures showed differing treatment and no merits-based finding had been recorded, the original authority had to examine the issue notice-wise and allow the appellant to adduce evidence. The proper course was fresh adjudication after hearing both sides, so the matter was remanded to the original authority for a de novo decision.

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Issues: Whether the matter should be remanded for fresh adjudication on the question of inclusion of octroi, transport, loading and unloading charges, manufacturing expenses and wastage in the assessable value of yarn.

Analysis: The dispute turned on whether the appellant had separately shown the relevant charges in each of the four show-cause notices, as claimed, or whether the department was justified in adding those elements to the assessable value where they were not separately declared. The record showed differing treatment in the annexures and the verification required issue-wise examination by the original authority. As no finding on merits was recorded and the appellant was to be allowed to produce evidence, the proper course was fresh adjudication after hearing both sides.

Conclusion: The matter was remanded to the original authority for de novo decision after granting a reasonable opportunity of hearing.

Ratio Decidendi: Where the correctness of valuation depends on factual verification of declarations and supporting records, and such verification has not been undertaken, the proper course is remand for fresh adjudication with opportunity to adduce evidence.

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