Assessable value includes pre-delivery contract-specific charges linked to manufacture and quality assurance of special fabrics.

Special checking charges and holding incidental charges recovered from industrial customers were includible in the assessable value because both arose before delivery at the factory gate and were integrally connected with manufacture of contract-specific special quality fabrics. The holding charges were treated as interest on working capital for stock retained in the factory, and the special checking charges as labour costs incurred to ensure delivery of the contracted quality. As they formed part of the total cost of manufacture and were not shown to be part of a lower normal price to other buyers, exclusion of the charges was rejected.

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Issues: Whether special checking charges and holding incidental charges recovered from industrial customers were includible in the assessable value of the special quality fabrics.

Analysis: The charges were recovered for customer-specific fabric manufactured under special contracts and were not shown to be part of a lower normal price charged to other buyers for the same goods. The holding charges represented interest on working capital for stock retained in the factory, while the special checking charges represented labour charges incurred to ensure delivery of the contracted quality. Both charges arose before delivery at the factory gate and formed part of the total cost of manufacture.

Conclusion: The charges were correctly treated as includible in the assessable value, and the contention to exclude them was rejected.

Final Conclusion: The appeal failed because the disputed charges were held to form part of the assessable value of the goods.

Ratio Decidendi: Charges incurred before delivery and integrally connected with manufacture and contract-specific quality assurance are includible in the assessable value.

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