Discount abatement in valuation cannot be denied where transaction-wise correlation is impracticable and records substantiate the claim.

Where stock transfers are sold through multiple outlets over time, denial of abatement for discounts merely because invoice-to-invoice correlation is impracticable is not sustainable. The commentary states that trade discounts actually passed on remain admissible in valuation, and substantive entitlement cannot be defeated by rigid procedural insistence when exact matching is commercially unrealistic. It also notes that Chartered Accountant certificates and consolidated sales data, verified from the books, can sufficiently support the claim where the Revenue produces no rebuttal evidence or workable alternative method. On that basis, blanket rejection of the abatement claim is treated as arbitrary and unsustainable.

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Issues: (i) Whether denial of abatement towards discounts is legally sustainable in the absence of transaction-wise correlation. (ii) Whether Chartered Accountant certificates and consolidated sales data are sufficient to establish the claim of abatement and whether outright denial of abatement is legally sustainable.

Issue (i): Whether denial of abatement towards discounts is legally sustainable in the absence of transaction-wise correlation.

Analysis: The assessee's goods were stock transferred to multiple outlets and sold over time, making strict one-to-one correlation between each clearance and each sale invoice impracticable. The insistence on such correlation was held to be contrary to commercial realities and an unrealistic burden in the context of the business model. The Court also relied on the principle that trade discounts actually passed on are admissible in valuation, and that substantive entitlement cannot be defeated by rigid procedural insistence where compliance is practically impossible.

Conclusion: Denial of abatement merely for want of transaction-wise correlation is not sustainable.

Issue (ii): Whether Chartered Accountant certificates and consolidated sales data are sufficient to establish the claim of abatement and whether outright denial of abatement is legally sustainable.

Analysis: The assessee produced voluminous sales data and Chartered Accountant certificates verified from the books of account, while the Department neither disproved the figures nor produced rebuttal evidence. In valuation matters, mathematical precision was held not to be mandatory where exact computation is impracticable, and a reasonable method based on available material must be adopted. The Department's rejection of the evidence solely because it was not transaction-specific was found arbitrary, and its failure to suggest any workable alternative method rendered the denial of the entire abatement unsustainable.

Conclusion: The evidence furnished by the assessee is sufficient, and the blanket denial of abatement is unsustainable.

Final Conclusion: The impugned order could not be sustained, and the assessee was entitled to the claimed relief on the basis of the evidence already on record.

Ratio Decidendi: Where the nature of trade makes invoice-to-invoice correlation impracticable, valuation cannot be defeated by insisting on rigid proof if the assessee produces reliable records showing discounts actually passed on and the Revenue fails to rebut them or adopt any reasonable alternative method.

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