Valuation of physician's samples must follow identical sold goods, with only permissible discount deductions, not cost-accounting reduction.

Physician's samples cleared free of cost were required to be valued by reference to the price of identical goods sold in the market, because the samples themselves were not sold and comparable sold goods were available. The cost-accounting argument was rejected as irrelevant where the comparable-goods method could be applied; it would arise only if that method were unavailable. The correct valuation basis was the sale price of identical goods, subject to any admissible discount deduction applicable to those goods, and the claim for a lower assessable value was rejected.

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Issues: Whether physician's samples cleared free of cost were required to be valued by reference to the price of identical goods sold in the market, and whether a lower assessable value could be adopted on the footing that the cost of such samples was already embedded in the cost of manufacture of saleable goods.

Analysis: The samples were not sold, while identical goods were available as sold comparable goods. In such a situation, valuation had to proceed on the basis of the comparable sold goods under Rule 6(b) of the Valuation Rules. The cost-accounting argument was held irrelevant because it would arise only where the comparable-goods method was unavailable. The correct basis, therefore, was the sale price of identical goods, with any admissible discount deduction applicable to those goods.

Conclusion: The samples were required to be valued at the same price as identical sold goods, subject to permissible discount deduction, and the assessee's claim for a lower valuation was rejected.

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