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Issues: Whether the cost of cylinders used for printing, recovered separately as cylinder making charges or engraving charges, was includible in the assessable value of the printed polyethylene films.
Analysis: The Tribunal noted that the issue had already been settled by prior decisions holding that the cost of cylinders used in printing forms part of the value of printed products. The appellate authority had relied on those decisions, including the larger bench view and the affirmance by the Apex Court, to hold that the separate recovery of cylinder charges did not keep them outside valuation. On that basis, the demand and the consequential interest and penalty were sustained.
Conclusion: The inclusion of cylinder making or engraving charges in the value of the printed polyethylene films was upheld, and the challenge to the demand failed.
Final Conclusion: The appeal was rejected and the order confirming duty, interest, and penalty was sustained.
Ratio Decidendi: Where cylinders are used for printing on excisable goods, their cost is includible in the assessable value notwithstanding separate recovery under a distinct invoice head.