Captive consumption valuation upheld where revised costing data and certified records supported the assessable value method.

Commissioner (Appeals) accepted revised costing data and a chartered accountant's certificate to recompute the assessable value of captively consumed intermediate goods. The Tribunal found that, on the facts, this valuation method was reasonable and supported by the record, and no legal or factual infirmity was shown by the Revenue. The appellate order setting aside the duty demand, interest, and penalty was therefore sustained, and the departmental appeal was rejected.

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Issues: Whether the Commissioner (Appeals) was justified in accepting the revised costing data and chartered accountant's certificate for determining the assessable value of captively consumed intermediate goods and in setting aside the duty demand, interest, and penalty.

Analysis: The appeal concerned the valuation of PPMFY, an intermediate product captively consumed in the manufacture of NWF. The record showed that the Commissioner (Appeals) accepted the revised costing data certified by the chartered accountant and directed recomputation of duty on that basis. The Tribunal found that, in the facts of the case, this approach was reasonable and saw no ground to interfere with the appellate order.

Conclusion: The valuation basis adopted by the Commissioner (Appeals) was upheld and the Revenue's challenge failed.

Final Conclusion: The appellate order in favour of the assessee was sustained and the departmental appeal stood rejected.

Ratio Decidendi: Where the appellate authority, on the facts and supported by certified costing data, adopts a reasonable method for valuing captively consumed intermediate goods, interference is not warranted unless the Revenue shows a legal or factual infirmity.

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