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Issues: Whether tikklies supplied with metal containers were to be treated as part of the containers for duty purposes and included in the assessable value.
Analysis: Item 46 of the Central Excise Tariff covered containers not otherwise specified, and Item 27 defined the meaning of containers. The explanation to Item 27 extended the concept of containers to articles in assembled or unassembled condition. Where the tin and tikklie were sold together, they constituted a container in unassembled form because the tikklie served as the closing part of the container. Accordingly, when cleared together, whether physically or constructively, duty was payable on the total value of the container including the tikklie.
Conclusion: The tikklies formed part of the container for assessment, and their value was includible in the assessable value. The decision was against the assessee and in favour of the Revenue.
Final Conclusion: Duty was held payable on the combined value of the containers and tikklies when cleared together as a single assessable unit.
Ratio Decidendi: Where a component sold with the main article serves as the closing or integral part of the article and the tariff contemplates assessment of the article in assembled or unassembled condition, the component's value is includible in the assessable value.