Valuation of galvanised pipes includes galvanisation cost where the process adds commercial value and improves marketability.

The cost of galvanisation is includible in the assessable value of galvanised M.S. pipes and tubes because the relevant excise question is valuation of the goods actually sold, not whether galvanisation constitutes manufacture. The pipes cleared from the factory gate were galvanised and commanded a higher wholesale price; galvanisation improved quality, increased longevity, enhanced marketability, and added commercial value. On that basis, the cost attributable to galvanisation formed part of the value realised on sale and could not be excluded merely because the process did not amount to manufacture under excise law.

---

---

Issues: Whether the cost of galvanisation is includible in the assessable value of galvanised M.S. pipes and tubes cleared by the manufacturer, even though galvanisation does not amount to manufacture under excise law.

Analysis: The pre-galvanisation product was a complete marketable excisable commodity, but the goods ultimately cleared and sold from the factory gate were galvanised pipes and tubes commanding a higher wholesale price. The legal question was therefore one of valuation under the excise provisions, not whether a fresh manufacture occurred. For valuation, the relevant criterion is the price of the excisable article as sold or capable of being sold, and the assessable value includes components that contribute to the intrinsic and commercial value of the goods up to the date of sale. Galvanisation improved quality, increased longevity, enhanced marketability, and added value to the product, so the cost attributable to that process formed part of the value realised on sale.

Conclusion: The cost of galvanisation is includible in the assessable value of the galvanised pipes and tubes, and the contention that it must be excluded because galvanisation is not manufacture is rejected.

---