Section 4A valuation for multi-piece packs requires aggregate MRPs when each item bears a separate price and can be sold individually.

Section 4A valuation for a multi-piece package depends on the package character and the markings on the individual items. Where each constituent item bears a clear MRP, is not marked as prohibited from separate sale, and can in fact be detached and sold separately, the circular on multi-piece packs requires duty to be computed on the aggregate of the individual MRPs rather than on a lower combined-pack MRP. On the recorded facts, the soap cakes retained separate MRPs and were capable of separate sale, so the combined pack was not assessed on the special combined MRP and the Revenue's valuation view was sustained.

---

---

Issues: Whether a combined pack of three soap cakes, each bearing an individual MRP and retained capable of separate sale, was assessable under section 4A on the MRP of the combined pack or on the aggregate of the MRPs printed on the individual items.

Analysis: The applicable valuation under section 4A depends on the character of the package and the markings on the individual items. The circular governing multi-piece packages clarifies that where individual items in a multi-pack bear clear, visible MRPs, are not marked as not to be sold separately, and can in fact be sold separately, duty is to be computed on the aggregate of the MRPs of the constituent pieces. On the facts recorded by the lower authorities, the individual soap cakes still bore their own MRPs, there was no indication on the individual packs that they were to be sold only as a set of three, and the cakes could be detached without mutilation. In the absence of contrary evidence, the factual findings supported application of the circular.

Conclusion: The combined pack was not entitled to assessment on the special combined MRP of Rs. 24/-. Duty was correctly required to be discharged on the aggregate MRP basis, and the Revenue's view was upheld.

Final Conclusion: The valuation adopted in the impugned orders was sustained, and the challenge to those orders failed.

Ratio Decidendi: For a multi-piece package with clearly visible MRPs on the individual items, where the items are capable of separate sale and are not marked as unsaleable separately, valuation under section 4A must be based on the aggregate of the individual MRPs rather than on a lower combined-pack MRP.

---