Deductibility of credit-sale interest from assessable value upheld where genuine credit period is shown in sale documents.

Interest attributable to genuine credit sales is deductible from the sale price when determining the assessable value of excisable goods. The Tribunal applied the larger bench view that such deduction is available for the credit period evidenced in the invoice or other duty-paying documents, and that the deduction must reflect the actual credit arrangement rather than a notional component of the wholesale cash price. On that basis, the assessee was entitled to exclude the receivable interest from assessable value.

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Issues: Whether interest on receivables arising from credit sales is deductible while determining the assessable value of excisable goods.

Analysis: The Tribunal applied the earlier larger bench view that interest attributable to credit sales is a permissible deduction from the sale price for arriving at the correct assessable value, and that such deduction is available for the credit period reflected in the invoice or other duty-paying documents. It also noted that the disallowance in the present case was based on the premise that the interest was built into the wholesale cash price, while no objection was raised that credit period was absent.

Conclusion: The deduction of interest on receivables is allowable, and the assessee is entitled to exclude it from the assessable value.

Ratio Decidendi: Interest attributable to a genuine credit sale is deductible from the sale price for determining assessable value, to the extent of the credit period evidenced by the relevant documents.

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