Job-worker valuation principle requires raw material value plus job charges; non-disclosure can justify the extended limitation period.

Job-worker valuation for repacking must be based on the raw material value received from the principal manufacturer, together with job charges, and the analysis states that excluding the principal manufacturer's 15% mark-up was a misapplication of the Ujagar Prints valuation principle. On limitation, non-disclosure of the valuation method and failure to file the required price declarations were treated as sufficient to justify the extended period, so the demand was held not barred by limitation. The commentary concludes that the appeal failed on both valuation and limitation, and the duty, interest and penalties were sustained.

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Issues: (i) Whether the assessable value of bulk Ultramarine Robin Blue received for repacking had to include the 15% mark-up forming part of the principal manufacturer's cost of production under the valuation regime applicable to job workers. (ii) Whether the demand was barred by limitation.

Issue (i): Whether the assessable value of bulk Ultramarine Robin Blue received for repacking had to include the 15% mark-up forming part of the principal manufacturer's cost of production under the valuation regime applicable to job workers.

Analysis: The appellant was a job worker repacking bulk goods received from the principal manufacturer. The valuation method applicable to a job worker required adoption of the value of the raw material as received, together with job charges, and not a truncated figure excluding the mark-up already forming part of the principal manufacturer's declared cost of production. The formula in Ujagar Prints was held to require valuation on the basis of raw material value and job work charges, and the appellant's exclusion of the 15% mark-up was treated as a misapplication of that principle.

Conclusion: The assessable value had to include the principal manufacturer's cost of production with the 15% mark-up, and the appellant's valuation method was rejected.

Issue (ii): Whether the demand was barred by limitation.

Analysis: The appellant had not disclosed the valuation method to the department in the relevant period and had failed to file the necessary price declarations. The first declaration was filed only later, and the omission was treated as sufficient to justify invocation of the extended period of limitation.

Conclusion: The demand was not barred by limitation and the extended period was held applicable.

Final Conclusion: The appeal failed on both valuation and limitation, and the order confirming duty, interest, and penalties was sustained.

Ratio Decidendi: A job worker must determine assessable value on the basis of the correct raw material value as received from the principal manufacturer, together with job charges, and suppression or non-disclosure of the correct valuation method can justify the extended period of limitation.

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