Notional interest on buyer advances is includible in assessable value only when the advance depresses the sale price.

Notional interest on interest-free advances from buyers is includible in the assessable value of excisable goods only when the Revenue proves that the advance actually influenced price fixation. If the advance results in a lower price, special discount, or other additional consideration, the amount may form part of assessable value; however, mere receipt of an interest-free advance is insufficient. Where the same selling price is charged to buyers with and without such advances, and there is no evidence that the advance depressed the price, notional interest cannot be added. The principle applied is that additional consideration must be shown by evidence and cannot be presumed from the existence of an advance.

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Issues: Whether notional interest on interest-free advances received from buyers is includible in the assessable value of excisable goods under the valuation provisions.

Analysis: Inclusion of notional interest depends on whether the advance actually affects the price charged for the goods. Where the advance leads to a lower price, special discount, or otherwise influences price fixation, the amount may form part of the assessable value as additional consideration. But the mere receipt of interest-free advances is not enough. If the same selling price is charged to buyers with and without such advances, and there is no evidence that the advances depressed the price, notional interest cannot be added. The reasoning is consistent with the valuation scheme requiring the price to reflect the normal price and with the principle that additional consideration must be shown by evidence, not presumed merely from the existence of an advance.

Conclusion: Notional interest on the advances was not includible in the assessable value in the absence of proof that the advances influenced the price; the appeals failed.

Ratio Decidendi: Notional interest on an advance from the buyer is includible in assessable value only when the Revenue proves that the advance influenced fixation of a lower sale price or other non-normal consideration; mere receipt of an interest-free advance does not justify addition.

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