Assessable value excludes transport-only packing when wooden crates are used solely for safe outstation carriage.

Packing charges are includible in assessable value only to the extent they relate to the packing in which goods are ordinarily sold. Additional wooden boxes or crates used merely for safe outstation transport were treated as secondary packing, not part of the normal sale packing, so their cost was excluded from assessable value. The note distinguishes cases where fragile goods require such packing as ordinary packing, but on these facts the primary packing was sufficient for clearance and the transport packing remained incidental to transit protection.

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Issues: Whether the cost of additional packing provided in wooden boxes or crates for outstation transportation was includible in the assessable value of the finished goods.

Analysis: The additional packing was provided only in a few cases for safe transport of goods and not as the ordinary manner in which the goods were sold. Packing ordinarily used for sale forms part of assessable value, but packing incurred merely to protect goods in transit does not. On the facts, the primary packing was sufficient for normal clearance, and the wooden boxes or crates were only secondary packing for transport. The contrary reliance placed on the glass-sheet decision was distinguished because that case involved fragile goods for which the wooden packing itself was necessary as normal packing.

Conclusion: The cost of the additional packing was not includible in the assessable value and the appeal was allowed.

Ratio Decidendi: Packing charges are includible only to the extent of the packing in which goods are ordinarily sold, whereas additional packing used solely for safe transportation is not part of assessable value.

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