Assessable value of flushing cistern parts turned on whether fittings were accessories or essential components, leading to remand.

Valuation of a flushing cistern depended on whether the handle assembly, ball valve assembly, overflow assembly, syphon assembly, outlet flange assembly and flush pipe assembly were accessories or essential parts for inclusion in assessable value. The Supreme Court noted that the Tribunal had treated the items as accessories and proceeded on the assumption that accessories were not includible, but the record did not show any proper examination of the manner in which the items were described in the bills or their functional relationship with the cistern. The appeals were allowed, the Tribunal's order was set aside, and the matter was remanded for decision in accordance with law.

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Issues: Whether the valuation of the flushing cistern required determination of whether the fittings described as handle assembly, ball valve assembly, overflow assembly, syphon assembly, outlet flange assembly and flush pipe assembly were accessories or parts of the cistern for inclusion in assessable value.

Analysis: The dispute turned on the character of the disputed items and whether their description in the bills prepared by the assessee could be disregarded. The Tribunal had treated the items as fittings or accessories and had proceeded on the footing that accessories were not includible in the assessable value. The record did not show that the Tribunal had examined whether, on the manner of description and the functional relationship with the cistern, the items were in truth accessories or essential parts.

Outcome: The appeals were allowed, the Tribunal's order was set aside, and the matter was remanded for decision in accordance with law.

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