Assessable value under excise law excludes post-manufacturing costs and profit, with delivery charges counted only if part of manufacture.

For valuation under Section 4 of the Central Excise Act, assessable value must reflect only the manufacturing element. Post-manufacturing expenses and profit are excluded from the wholesale price, and delivery-related items such as service charges, insurance, packing charges and similar components cannot be added mechanically unless they are shown to form part of manufacturing cost. The proper approach is to identify the allowable components on that principle before computing duty. On that basis, the challenged valuation order and consequential notices could not be sustained.

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Issues: Whether, for the purpose of valuation under Section 4 of the Central Excise Act, 1944, post-manufacturing expenses and profit could be included in the wholesale price or assessable value of sheet glass.

Analysis: The levy of excise duty under Section 3 is attracted to goods specified in the First Schedule, while Section 4 prescribes the method of computing value for duty. On the established authorities relied upon by the Court, the assessable value must reflect the manufacturing element only, and post-manufacturing cost and profit are not part of the price on which excise is levied. Items such as service charges, insurance charges, packing charges and other delivery-related components cannot be mechanically included without examining whether they are truly part of manufacturing cost. The proper course was for the revenue authorities to determine the allowable components in the light of this principle.

Conclusion: Post-manufacturing cost and profit are excluded from the assessable value under Section 4, and the impugned valuation order and consequential notices could not stand.

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