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Issues: Whether the assessable value of goods processed by a job worker for a principal manufacturer had to be determined on the basis of the principal's wholesale selling price or on the basis of the cost of raw materials, job work charges, manufacturing expenses and manufacturing profit.
Analysis: The valuation had to follow the principle laid down in the clarificatory order in Ujagar Prints, under which the processor is treated as effecting a deemed sale at the deemed factory gate. The assessable value is confined to the value of raw materials, the value of job work, and the manufacturing profit and expenses attributable to processing. The price at which the principal manufacturer sells the finished product in the wholesale market is not the proper assessable value where the facts disclose a job-work arrangement governed by that principle.
Conclusion: The assessable value was correctly to be determined on the Ujagar Prints basis and not on the principal manufacturer's wholesale market price, so the appeal failed.
Ratio Decidendi: In a job-work manufacturing arrangement, excise valuation must be confined to the value added by the processor at the deemed factory gate and cannot include the principal's subsequent wholesale selling price.