Assessable value of industrial fans excludes inlet and outlet dampers treated as accessories, not integral regulators.

The cost of inlet and outlet dampers used with industrial fans was not includible in the assessable value of the fans because the dampers functioned as accessories for regulating air intake and discharge, not as integral parts of the fan mechanism. The record showed they were fitted on the casing sides, and there was no technical material establishing that they were commercially understood as regulators of industrial fans. On that basis, their value could not be added to the fans' assessable value, and the Revenue's challenge failed.

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Issues: Whether the cost of inlet and outlet dampers was includible in the assessable value of industrial fans as being regulators of the fans.

Analysis: The dispute turned on the character of dampers used with industrial fans. The record supported the finding that the dampers were fitted on the sides of the casing and functioned as accessories for regulating intake and discharge of air, but not as integral components of the fan mechanism itself. In the absence of technical material showing that they were commercially understood as regulators of industrial fans, their cost could not be treated as part of the assessable value of the fans.

Conclusion: The cost of inlet and outlet dampers was not includible in the assessable value of industrial fans, and the Revenue's appeal failed.

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