Excise valuation of trailer accessories: detachable items were not integral parts and could not be added to assessable value.

Items attached to a trailer, including a tool-box, folding pole, jack, angles supporter, chains, brake-pipe, pipe stand, draw-bar and tomy, were held to be accessories rather than component or integral parts. Because the trailer was complete and usable without them, and the items could be fitted separately, they were not treated as part of the trailer's assessable value for excise duty. The court applied the principle that only items shown to be essential constituent parts of the manufactured article can be included in valuation, and the impugned orders were set aside.

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Issues: Whether the items attached to a trailer, namely tool-box, folding pole, jack, angles supporter, chains, brake-pipe, pipe stand, draw-bar and tomy, were components or integral parts of the trailer so as to form part of its assessable value for excise duty.

Analysis: The trailer was complete and usable even without the disputed items. The items were capable of being fitted separately and were in the nature of accessories rather than essential constituent parts. Unless an item is shown to be a component or integral part without which the manufactured article is incomplete, it cannot be treated as part of the trailer for excise valuation.

Conclusion: The items were not components or integral parts of the trailer and were not includible in the assessable value for excise duty. The petition succeeded and the impugned orders were set aside.

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