Proof of abatement claims requires reliable records; unsupported freight and container-rent deductions may be remitted for redetermination.

Where deduction from assessable value is claimed for freight and rent on containers, the claimant must substantiate the quantum with reliable records. The admissibility of such deductions was not disputed, but the extent of the abatement had to be proved through books of accounts, invoices, certificates and other supporting material. In the absence of evidence showing how container rent was computed, when it became chargeable, the applicable rate, or whether it was reflected in invoices, the full claim could not be accepted. Likewise, unsupported freight claims, including on ex-factory and depot sales, required fresh determination of the allowable abatement in accordance with law.

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Issues: Whether the assessee had proved the quantum of deduction or abatement claimed from the wholesale price on account of freight and rent on containers.

Analysis: The admissibility of deduction for rent on containers and freight was not in dispute; the controversy was confined to the extent of deduction claimed. In such cases, the assessee claiming abatement bears the burden of producing the necessary data, books of accounts, invoices, and certificates to establish the basis and extent of the claim. The record did not show the basis on which rent on containers was computed, when it became chargeable, the rate at which it was chargeable, or whether it was reflected in the invoices. On freight, part of the sales was ex-factory and part from depots, but no reliable evidence was led to justify the amount claimed as actual freight. The findings allowing the full claim were therefore unsupported by material evidence.

Conclusion: The assessee had not established the quantum of deduction claimed for freight and rent on containers, and the matter had to be remitted for fresh determination of the allowable abatement in accordance with law.

Ratio Decidendi: Where deduction from assessable value is claimed, the claimant must substantiate the quantum with reliable records and evidence; in the absence of such proof, the claimed abatement cannot be accepted as such and may be remitted for proper determination.

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