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Issues: Whether the value of durable packing material supplied by the buyer was includible in the assessable value of the manufactured goods.
Analysis: The goods manufactured were chemicals falling under Chapters 28 and 38 and were marketable as such. The packing material supplied by the buyer was not integral to making the goods marketable. The issue was already covered by prior Tribunal decisions and the marketability test militated against addition of the packing value to assessable value.
Conclusion: The value of the buyer-supplied durable packing material could not be added to the assessable value, and the assessee succeeded on the merits.