Installation charges after factory clearance are not part of assessable value for Central Excise duty when goods were already manufactured and duty-paid.

Installation charges separately recovered through invoices or debit notes were held not to form part of the assessable value for Central Excise duty where the goods had already come into existence at the manufacturer's premises, duty had been paid before clearance, and installation took place only later at the purchaser's premises. The Board's clarification on charges relating to bringing excisable goods into existence at the buyer's premises was treated as inapplicable, and the earlier Tribunal view on post-manufacture installation charges was applied. The appeals were allowed.

---

---

Issues: Whether installation charges separately recovered through invoices or debit notes were includible in the assessable value of goods for Central Excise duty.

Analysis: The goods had already come into existence at the manufacturer's premises and duty had been paid before clearance from the factory. In that situation, the Board's clarification regarding installation and commissioning charges for bringing excisable goods into existence at the purchaser's premises did not apply. The earlier Tribunal decision holding that installation charges for equipment already manufactured were not includible in assessable value was treated as directly applicable.

Conclusion: Installation charges were not includible in the assessable value, and the appeals were allowed.

Ratio Decidendi: Where goods are manufactured, cleared on payment of duty, and installation is undertaken thereafter at the purchaser's premises, separate installation charges are not part of the assessable value for Central Excise duty.

---