Assessable value depends on substantive pricing, and invoice wording alone cannot defeat a trade discount.

For valuation purposes, the real substance of the pricing arrangement governs assessable value, and a mere change in invoice description does not alter entitlement to a trade discount. The material period pricing was treated as the same in substance as the later arrangement of supplying 13 pieces for the price of 12, even though the invoice described the 13th piece as a "gift". On that basis, the invoice presentation was held not to affect assessable value, and the assessee was entitled to the discount.

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Issues: Whether the manner of showing the 13th piece of talcum powder as a 'gift' in the invoice, instead of reflecting it as a sale of 13 pieces for the price of 12, affected the assessable value and the assessee's entitlement to the discount.

Analysis: The pricing pattern during the material period was found to be the same in substance as that followed later, namely supply of 13 pieces for the price of 12. The difference lay only in the form of declaration in the invoices. Such a change in invoice presentation was held not to alter the real nature of the transaction or the assessable value.

Conclusion: The assessee was entitled to the discount, and the revision application was allowed.

Final Conclusion: The order in appeal was set aside and the assessee succeeded on the question of assessable value, as the invoice description did not affect the substantive pricing arrangement.

Ratio Decidendi: For valuation purposes, the assessable value is determined by the real substance of the pricing arrangement, and a mere change in the form of invoice declaration does not alter the entitlement to a trade discount.

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