Taxable value of repair service cannot include separately invoiced material cost for replacement of damaged container parts.

The cost of goods supplied during repair and replacement of damaged container parts could not be added to the taxable value of the repair and maintenance service where the invoices separately showed labour and material charges and the materials used were supported by the record. The dispute was treated as covered by the appellant's earlier final order on the same issue, and the addition of repair material cost to the taxable value was held unsustainable.

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Issues: Whether the cost incurred for replacement and repairs of damaged container parts used in international transportation was liable to be added to the taxable value of the repair and maintenance service.

Analysis: The dispute was treated as covered by the appellant's own earlier final order on the same issue. The invoices were found to separately indicate the labour amount and material amount, with the materials used reflected in the documentary record. It was therefore held that the cost of goods supplied during repair could not be added to the value of the taxable service.

Conclusion: The addition of the repair material cost to the taxable value was held to be unsustainable, and the appeal succeeded.

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