Packing cost in wholesale marketing forms part of assessable value unless the packing is durable and returnable.

The cost of a reel centre core used for winding paper was held includible in assessable value for central excise because packing used in wholesale marketing forms part of value under section 4(4)(d)(i), unless it is durable and returnable by the buyer. The reel centre core was treated as packing within the statutory explanation, and no case was made that it fell within the exclusion for durable returnable packing. The excise valuation adopted by the lower authorities was therefore sustained.

---

---

Issues: Whether the cost of the reel centre core used for winding paper was includible in the assessable value of the paper for central excise purposes.

Analysis: Section 4(4)(d)(i) of the Central Excises and Salt Act, 1944 expressly includes the cost of packing in the assessable value where goods are delivered in packed condition, except for packing of a durable nature and returnable by the buyer. The reel centre core was treated as packing within the statutory explanation, and there was no claim that it was durable and returnable packing. The cost of packing generally used in wholesale marketing is includible in assessable value.

Conclusion: The cost of the reel centre core was includible in the assessable value of the paper.

Final Conclusion: The appeal failed and the excise valuation adopted by the lower authorities was sustained.

Ratio Decidendi: Packing material used in the course of wholesale marketing forms part of assessable value unless it is durable and returnable by the buyer.

---