Assessable values cannot be revised on assumptions of under-disclosed cost and profit merely because excise duty increased.

The Court held that a revised price list and revised assessable values for cigarettes could not be compelled on the unsubstantiated assumption that the manufacturer had failed to absorb the increase in excise duty or had under-disclosed manufacturing cost and profit. Because the price list had already been approved on the basis of the declared wholesale prices and assessable values, the authority could not substitute those figures with a notional net sum realised after duty at the concessional rate. The communication demanding reassessment on that basis was therefore invalid and was quashed.

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Issues: Whether the demand for a revised price list and revised assessable values for cigarettes, on the assumption that the increase in excise duty could not be absorbed by the manufacturer, was justified; and whether the communication requiring assessment on the basis of the net sum realised after payment of duty at the earlier concessional rate could stand.

Analysis: The price list had already been approved on the basis of the petitioners' declared wholesale prices and assessable values. The impugned communication proceeded on an assumption that the manufacturing cost and manufacturing profit had not been correctly disclosed, and that the earlier assessable values should be replaced by figures equating the combined manufacturing cost and profit with the net amount realised after payment of duty at the concessional rate. The Court found no justification for that assumption or for the consequent demand for a fresh price list based upon it.

Conclusion: The demand for a revised price list and the revised assessable values was unsustainable and the impugned letter was quashed and set aside, in favour of the petitioners.

Final Conclusion: The administrative insistence on revising assessable values on the stated premise was invalid, and the petition succeeded with the impugned communication annulled.

Ratio Decidendi: An assessing authority cannot compel a revised price list or alter assessable values on the basis of an unsubstantiated assumption that the manufacturer must have under-disclosed cost and profit merely because duty has increased.

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