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Issues: Whether the value of PP caps was liable to be added to the value of metal containers for determining the assessable value of the containers for central excise duty.
Analysis: The petitioners contended that the containers were complete excisable products by themselves and that the caps were supplied under separate orders, often in different quantities, with duty being paid separately on the caps. The Government accepted that the caps were not necessarily integral to the containers and that there was force in the contention that their value should not be universally added to the value of the containers for assessment.
Conclusion: The addition of the value of PP caps to the assessable value of the containers was not justified, and the revision application was allowed with consequential benefits to the petitioners.