Assessable value of transformers excludes transformer oil sent directly to the installation site and never received in the factory.

Transformer oil directly despatched from the oil manufacturer to the installation site, without ever being received in the transformer manufacturer's factory, was not part of the goods cleared from the factory. On those facts, its value could not be added to the assessable value of the transformers, because the oil did not form an integral component of the manufactured goods at the point of clearance. The duty demand based on inclusion of that oil value was therefore unsustainable.

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Issues: Whether the value of transformer oil, directly despatched from the oil manufacturer to the site of installation and never brought to the factory of the transformer manufacturer, was includible in the assessable value of transformers.

Analysis: The transformer oil was not received at the manufacturer's factory and was supplied directly from the place of production to the site where the transformer was to be installed. On these facts, the oil did not form part of the goods as cleared from the factory, and its value could not be added for determining the assessable value of the transformers.

Conclusion: The value of transformer oil was not includible in the assessable value of the transformers, and the duty demand on that basis was unsustainable.

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