Assessable value excludes non-essential packing charges and allows uniformly granted cash discount in wholesale valuation.

Special packing charges for cardboard boxes or wooden crates used only for long-distance dispatches were excluded from the assessable value because such packing was not essential for marketing the fabrics. A uniformly granted cash discount to buyers paying in cash was also deductible, as the relevant valuation basis was the wholesale cash price. The valuation claims were therefore accepted, and the assessee's assessable value was reduced accordingly.

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Issues: (i) whether special packing charges for card board boxes or wooden crates were includible in the assessable value of fabrics; (ii) whether special discount in the nature of cash discount was deductible while determining assessable value.

Issue (i): whether special packing charges for card board boxes or wooden crates were includible in the assessable value of fabrics.

Analysis: The goods were ordinarily sold in thans after normal packing in polythene covers, and special packing in card board boxes or wooden crates was undertaken only for long-distance dispatches. Since such special packing was not essential for marketing the goods and a substantial portion of sales had been made without it, the charges were not part of the assessable value.

Conclusion: The special packing charges were not includible in the assessable value, in favour of the assessee.

Issue (ii): whether special discount in the nature of cash discount was deductible while determining assessable value.

Analysis: The declared prices were mudat prices, and cash discount was uniformly granted to buyers who paid in cash. As the assessment basis at the relevant time was the wholesale cash price, deduction of the cash discount was proper for arriving at the assessable value.

Conclusion: The special discount was deductible in computing assessable value, in favour of the assessee.

Final Conclusion: The order in appeal was upheld and the review proceedings were dropped, leaving the assessee's valuation claims accepted.

Ratio Decidendi: Charges for packing that are not essential to market the goods are not includible in assessable value, and a uniformly allowed cash discount deductible from the wholesale cash price must be excluded in valuation.

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