Assessable value of goods and inclusion of straw packing in excise valuation required reconsideration under the governing packing test.

The assessable value of china and porcelain goods was disputed on the question whether the value of straw packing used in manufacture and clearance formed part of excise duty valuation. The Tribunal had treated straw packing value as always includible, even where ordinary sales were made without packing, but that approach was required to be tested against the later valuation principle governing packing material. The existing reasoning was not finally accepted, and the matter was remitted to the Tribunal for fresh disposal in accordance with law.

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Issues: Whether the value of straw packing used in the manufacture and clearance of china and porcelain goods was includible in the assessable value for excise duty.

Analysis: The dispute turned on the proper test for inclusion of packing material in assessable value. The Tribunal had held that the value of straw packing must always be included, even where the assessee's ordinary sales were without packing. The matter was required to be examined in the light of the principle laid down in the later decision governing valuation of packing material, and the matter therefore called for reconsideration according to that test.

Conclusion: The inclusion of straw packing value was not finally upheld on the existing reasoning, and the matter was sent back to the Tribunal for fresh disposal in accordance with law.

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