Assessable value includes packaging materials and interleaving costs where they are essential to marketability.

Cost of tissue paper used as interleaving between layers of aluminium tea chest lining foil, and the cost of the interleaving operation, were includible in the assessable value because the goods were cleared at the factory gate in that packed condition. The interleaving was part of the packaging process that made the goods marketable, and materials or operations essential to marketability form part of manufacture for valuation purposes. An earlier authority cited by the appellant was distinguished in light of later Supreme Court authority. The taxable value therefore included both the tissue paper and the interleaving operation.

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Issues: Whether the cost of interleaving tissue paper and the cost of the interleaving operation were includible in the assessable value of aluminium tea chest lining foil cleared at the factory gate.

Analysis: The tissue paper was used between two layers of foil for protection and formed part of the packaging process by which the goods were made marketable. Since the foils were cleared in that packed condition, the tissue paper and the operation of interleaving were not separable from the process of making the goods marketable. The earlier decision relied upon by the appellant was distinguished on the basis of later Supreme Court authority holding that materials or operations essential to marketability form part of the manufacture and their cost enters the assessable value.

Conclusion: The cost of the tissue paper and the interleaving operation was rightly included in the assessable value, and the appeal failed.

Ratio Decidendi: Materials and operations essential to make excisable goods marketable form part of the assessable value.

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