Excise valuation precedent must fit the facts before it is applied to captively consumed goods and remand follows.

Excise valuation of captively consumed goods requires comparison with the factual matrix of the precedent before it is applied; even a small factual distinction may affect the result. The Supreme Court noted that the Tribunal had relied on an earlier valuation ruling without first examining whether the present case differed materially or whether Rule 6 of the Central Excise Valuation Rules, 1975 had bearing on the valuation exercise. The matter was therefore remitted for fresh consideration of the facts and the applicability of the earlier decision, and the assessee succeeded to that extent.

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Issues: Whether the valuation of goods captively consumed had to be determined on the basis of the market price of goods directly sold, and whether the earlier decision applied without first examining the factual differences and the relevance of Rule 6 of the Central Excise Valuation Rules, 1975.

Analysis: The dispute concerned valuation of goods largely captively consumed, with only a small portion sold in the spare parts market. The Court noted that the Tribunal had relied on the earlier decision on excise valuation, but had not examined whether the factual setting in the present case was materially different or whether the department's reliance on Rule 6 of the Central Excise Valuation Rules, 1975 had substantial bearing. The Court emphasised that precedent must be applied only after considering the factual matrix and that even a small factual difference may alter the legal result. In those circumstances, the Court found it appropriate to remit the matter for fresh consideration on the factual aspect and on the applicability of the earlier decision to the present case.

Conclusion: The matter was remitted to the Tribunal for reconsideration of the factual position and the applicability of the earlier valuation ruling; the assessee succeeded to that extent.

Final Conclusion: The valuation dispute was not finally decided on merits, and the Tribunal was directed to re-examine the case in light of the relevant factual distinctions and the governing valuation rules.

Ratio Decidendi: A precedent on excise valuation must be applied only after determining whether the facts materially match the earlier case, and valuation provisions governing ascertainable and unascertainable prices must be examined in that factual context.

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