Assessable value includes essential cardboard cartons where primary packing cannot withstand wholesale storage, handling, and transport.

Cardboard cartons used to market soap and detergent powder were held to form part of the assessable value because they were essential for wholesale delivery at the factory gate. The primary wrappings for the goods were too flimsy to withstand storage, handling, and transport, so the goods could not reach the wholesale market in primary packing alone. The cartons were therefore not optional outer packing but necessary packing for marketability in wholesale trade, making their cost includible in valuation.

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Issues: Whether the cost of cardboard cartons used for marketing soap and detergent powder was includible in the assessable value of the goods.

Analysis: The cartons were found to be essential for wholesale delivery at the factory gate. The primary wrappings for the soap cakes and detergent powder were too flimsy to withstand storage, handling, and transport, and the goods, by their nature, could not be brought to the wholesale market in primary packing alone. The cartons were therefore not optional outer packing but necessary packing for marketability in wholesale trade.

Conclusion: The cost of the cardboard cartons was includible in the assessable value and the appeals failed.

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