Depot valuation requires duty to be computed on all clearances, and final remand directions must be followed in reassessment.

In depot-based valuation disputes, duty liability must be re-quantified on the basis of all relevant clearances taken together, rather than by isolating only those depot sales realised at a higher price. Where an earlier remand has fixed the computation method and that direction has attained finality, the adjudicating authority must follow it strictly while re-working the demand and afford an opportunity of hearing. The matter was therefore remanded for recomputation of duty in accordance with the earlier Tribunal directions.

---

---

Issues: Whether the duty liability arising from depot clearances was required to be re-quantified by taking into account the entire clearances and not only the clearances sold at higher depot prices.

Analysis: The earlier remand had directed that the assessee's liability must be computed on the basis of the entire clearances and that the Revenue could not isolate only those depot sales which fetched a higher value while ignoring clearances ultimately sold at a lower value. The assessee had also placed a detailed statement regarding duty computation before the adjudicating authority. Since the Revenue had not challenged the earlier remand order and the method of calculation prescribed therein had attained finality, the adjudicating authority was required to follow that basis strictly and re-work the duty demand accordingly, after granting an opportunity of hearing.

Conclusion: The duty liability was required to be re-quantified in accordance with the earlier remand directions, and the matter was remanded to the adjudicating authority.

Final Conclusion: The appeal succeeded by way of remand, with the impugned order set aside and the duty computation left to be redetermined on the basis earlier fixed by the Tribunal.

Ratio Decidendi: In depot-based valuation disputes, duty liability must be determined on the basis of all relevant clearances taken together, and the adjudicating authority must comply with the final directions governing the method of computation when re-quantifying the demand.

---