Cash discount for advance payment is deductible from assessable value where payment precedes delivery and the label does not change character.

A 2% discount allowed only to buyers who paid before delivery was treated as a cash discount for valuation purposes because it applied to cash-and-carry transactions rather than credit sales. Its deductibility did not depend on every buyer availing it, and its label as an advance payment discount did not change its legal character. The discount was therefore admissible and deductible from assessable value, and the Revenue's challenge failed.

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Issues: Whether the 2% advance payment discount given to buyers who paid before delivery of goods was a deductible cash discount while determining assessable value.

Analysis: The discount was confined to buyers who made payment before taking delivery, distinguishing cash-and-carry transactions from credit sales. Such a discount, though described as an advance payment discount, was in substance a cash discount. The fact that not all buyers availed the benefit did not affect its deductibility, and the description given to the discount did not alter its legal character for valuation purposes.

Conclusion: The discount was admissible as a cash discount and deductible from assessable value. The Revenue's appeal had no merit.

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