Equalised freight after manufacture is excluded from excise assessable value because only manufacture-based value is taxable.

Equalised freight charged uniformly on despatch of goods was treated as a post-manufacturing element and not part of the value assessable to central excise duty. The analysis states that excise is attracted by manufacture, not by subsequent transportation or clearance-related costs, and that recovery of freight at the time of factory clearance does not convert it into manufacturing cost. On that basis, uniform freight charged for pricing convenience was held not includible in assessable value, and the demand and revisional order were unsustainable.

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Issues: Whether equalised freight charged uniformly on despatch of goods formed part of the assessable value for central excise duty.

Analysis: Excise is attracted by the incidence of manufacture, not by post-manufacturing operations. The freight was incurred in sending the consignments and was charged uniformly only as a matter of pricing convenience. Such freight did not cease to be a post-manufacturing element merely because it was recovered when the goods left the factory, and there was no warrant for treating it as part of the manufacturing cost or assessable value.

Conclusion: Equalised freight was not includible in the assessable value. The demand and revisional order were unsustainable and the writ petition succeeded.

Ratio Decidendi: For central excise, only the value attributable to manufacture is assessable, and uniform freight charged after manufacture cannot be included merely because it is recovered at the stage of clearance from the factory.

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