Necessary packing costs excluded from assessable value where wooden cases and cardboard boxes were essential for transport and marketing.

Packing that is necessary for transporting and marketing goods is not includible in assessable value. The Supreme Court note states that wooden cases and cardboard boxes used for packing electrodes were treated as essential packing, and earlier decisions had already concluded the point against the revenue. On that basis, the cost of those packing materials was excluded from assessable value, and the issue was resolved in favour of the assessee.

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Issues: Whether the cost of wooden cases and cardboard boxes used for packing electrodes was includible in the assessable value of the goods.

Analysis: The packing was found to be necessary for transporting and marketing the electrodes. The point was treated as concluded against the revenue by the earlier decisions relied upon by the Tribunal, and no contrary merit was found in the appeals.

Conclusion: The cost of the wooden cases and cardboard boxes was not includible in the assessable value; the issue was decided in favour of the assessee.

Ratio Decidendi: Where packing is necessary for transporting and marketing the goods, its cost is not includible in the assessable value.

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