Assessable value of plant drawings and documents depends on whether they relate to manufacture or site erection.

Charges for drawings and documents connected with erection of a caustic evaporation plant were examined for inclusion in assessable value, but most of the disputed material consisted of site-related engineering documents, such as layout, process, piping, electrical and approval drawings, which were treated as relating to the plant at site rather than to goods cleared from the factory. Equipment fabrication drawings and certain piping material specification or erection-related drawings required further examination because they could affect manufacture of supplied components. The inclusion issue was therefore not conclusively resolved on the existing record, and the matter was remitted for reconsideration of those identified charges and the linked exemption and penalty questions.

---

---

Issues: Whether the charges paid for drawings and documents relating to the erection of a caustic evaporation plant were includible in the assessable value of the goods cleared for duty.

Analysis: The dispute concerned drawings and documents separately contracted for, apart from the supply of main equipment. The disputed items were largely engineering and site-related documents such as plot plans, process flow diagrams, piping and electrical drawings, equipment layouts, foundation drawings and approval drawings. Such items were treated as relating to the plant as it would exist at site, and not as charges directly attributable to the manufacture of the goods cleared from the factory. However, item 22, described as equipment fabrication drawings, and the reference to piping material specification and certain erection-related drawings were found to require further examination because they could bear on manufacture of components supplied under the contract. The issue was therefore not finally capable of being decided on the existing material.

Conclusion: The inclusion of the disputed charges in the assessable value was not finally upheld; the matter was remitted for reconsideration of the two identified charges and consequential exemption and penalty issues.

---