Interest on receivables cannot be deducted from assessable value unless an embedded interest element in the sale price is proved.

Interest on receivables was claimed as a post-manufacturing expense for deduction from the assessable value of goods, but the claim required proof that the sale price actually included an identifiable interest component built into the price structure. The mere fact that the interest element was not separately shown in depot invoices was insufficient. On the stated facts, the assessee did not establish that the charged price contained such an embedded interest element, so the deduction was not allowable and the valuation claim failed.

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Issues: Whether interest on receivables claimed as a post-manufacturing expense was deductible from the assessable value of the goods.

Analysis: The assessee sought abatement for interest on receivables on the footing that it formed part of the price structure for depot sales and that the same price was charged whether payment was made within or beyond the general credit period. Deduction was not justified merely because the interest element was not separately shown in depot invoices. To succeed, the assessee had to establish that the price charged actually contained an identifiable element of interest built into it, in accordance with the governing law on valuation.

Conclusion: The claim for deduction of interest on receivables was not proved and was therefore not allowable; the issue is decided against the assessee and in favour of the Revenue.

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