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Issues: Whether, under a composite contract for manufacture, transportation, laying and jointing, testing, and maintenance charges are includible in the assessable value of the pipes.
Analysis: The contract price was found to consist of manufacturing cost and profit on the one hand and charges for transportation, laying and jointing, testing, and maintenance on the other. Transportation from the factory gate to the site was treated as a separate post-clearance element and, following the settled principle excluding such cost from assessable value, was held not includible. Laying and jointing, testing, and maintenance were treated as post-manufacturing activities and not as part of the manufacturing process. The contract being composite, the expenditure attributable to execution work was regarded as separable from the value of the manufactured goods.
Conclusion: The disputed transportation, laying and jointing, testing, and maintenance charges were held not includible in the assessable value, and the matter was sent back for redetermination of value accordingly.