Assessable value excludes post-clearance printing cost on PVC film where no new excisable product emerged.

Printing undertaken on PVC film/sheeting after clearance from the manufacturing unit was held not to form part of the assessable value where the activity was carried out in a separate factory across the road, the record did not show that it was part of the same manufacturing premises, and the PVC film was already complete when it came into existence. As the Revenue did not establish that printing was necessary to complete the original product or that a new excisable product emerged merely because of printing, the printing cost could not be added again to the assessable value.

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Issues: Whether the cost of printing undertaken on PVC film/sheeting after clearance from the manufacturing unit is includible in the assessable value.

Analysis: The printing activity was carried out in a separate factory across the road, and the record did not show that it formed part of the same manufacturing premises. The PVC film was already complete when it came into existence, and the Revenue did not establish that printing was necessary for completion of the original product or that a new excisable product emerged merely because of printing. In these circumstances, the cost of printing could not be added again to the assessable value.

Conclusion: The cost of printing was not includible in the assessable value, and the Revenue's challenge failed.

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