Packing cost in excise valuation includes non-returnable glass containers used for food products.

The cost of glass containers used to pack food products was treated as part of the assessable value under the excise valuation provision because there was no categorical basis to treat the containers as returnable packing. Consumers would ordinarily not return such containers to traders, and the procurement of second-hand bottles for filling did not establish returnability in ordinary trade. As the goods were cleared in packed condition, the packing cost formed part of the normal price for valuation purposes, and the revision application failed.

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Issues: Whether the cost of glass containers used for packing food products was includible in the assessable value under the excise valuation provision.

Analysis: The Government found that there was no categorical basis to treat the glass containers as returnable to the manufacturer. Consumers of food products in such containers would ordinarily not return them to the traders, and the fact that second-hand bottles were also procured for filling did not establish durability in the ordinary trade sense. Since the goods were removed in packed condition, the cost of packing formed part of the normal price under the relevant statutory provision.

Conclusion: The cost of the glass containers was includible in valuation, and the revision application failed.

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