Comparable goods valuation under Rule 6(b) requires consideration of all relevant sale invoices and reasoned comparability findings.

Valuation of captively consumed resin coated sand under Rule 6(b) had to be based on actual sale prices of comparable goods, whether manufactured by the assessee or another assessee. Because the department relied on one invoice while the assessee produced other invoices showing lower comparable sales that were not addressed, the valuation could not stand. The authority was required to consider both sets of invoices and record reasons on comparability, including any differences in quality or composition. The order was set aside and the matter remitted for fresh adjudication on a reasoned comparison of the competing prices.

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Issues: Whether the assessable value of resin coated sand captively consumed in manufacture of cast iron castings was to be determined under Rule 6(b) on the basis of comparable goods and whether the price of the assessee's own comparable sales evidence was improperly ignored.

Analysis: Rule 6(b) required valuation with reference to comparable goods manufactured by the assessee or by another assessee, and the comparable price had to be the actual sale price of such goods. The record showed reliance by the department on one invoice from another manufacturer, but the appellants had also produced invoices showing lower sales of comparable goods, which were not dealt with by the original authority. Where competing comparable prices were available, the authority was required to consider both sets of invoices and give reasons for accepting one and rejecting the other, including any difference in quality or composition.

Conclusion: The original valuation could not be sustained as passed, and the matter had to be reconsidered after examining the ignored invoices and recording reasons on comparability.

Final Conclusion: The appeal succeeded only to the extent that the valuation order was set aside and the matter was sent back for fresh adjudication on a reasoned comparison of the competing prices.

Ratio Decidendi: Under Rule 6(b), valuation of captively consumed goods must be based on a reasoned comparison with actual sale prices of comparable goods, and relevant comparable evidence cannot be ignored without explanation.

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