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Issues: (i) Whether the value of raw materials supplied free of cost by the customer was includible in the assessable value of the job-worked goods cleared by the appellant.
Analysis: The appellant received materials from customers under challans for job work, and the customers had already availed CENVAT credit on the supplied materials. The dispute was whether such free-supplied inputs could be added to the value of the processed goods under the valuation rules. The cited precedent on intermediate goods manufactured by a job worker was found to apply, and the contrary authorities relied on by the Revenue were treated as distinguishable.
Conclusion: The value of the free-supplied raw materials was not includible in the assessable value, and the demand was unsustainable.
Final Conclusion: The appeal succeeded and the valuation adopted by the lower authorities was set aside, with consequential relief.
Ratio Decidendi: Where goods are processed by a job worker from customer-supplied materials on challans and the customer has availed credit on those materials, the value of the free-supplied inputs cannot be added to the assessable value of the finished or intermediate goods.