Show cause notice limits valuation demands: assessable value cannot be enlarged on a ground not alleged in the notice.

A valuation demand for component parts could not be sustained where the show cause notices did not allege short-assessment from failure to include the proportionate cost of moulds, dies and tools. The notices were confined to alleged clearances and non-payment of duty on the tools, moulds and dies themselves, so the adjudicating and appellate authorities could not travel beyond that foundation to enhance the assessable value of the components. The operative principle is that a demand or valuation adjustment must stay within the case made in the notice, and a new basis cannot be introduced at adjudication or appeal.

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Issues: Whether, in the absence of an allegation in the show cause notices, the cost of moulds, dies and tools could be included in the assessable value of the component parts manufactured by the assessee.

Analysis: The notices were confined to alleged clearances and non-payment of duty in respect of tools, moulds and dies. They did not allege that duty on the component parts had been short-assessed by failure to include the proportionate cost of those items in their assessable value. A demand cannot be sustained on a basis not put to the assessee in the notice, and the appellate authority could not travel beyond the scope of the notices to enhance the valuation of the components.

Conclusion: The inclusion of the cost of moulds, dies and tools in the assessable value of the component parts was not permissible on the basis of the notices issued, and the Department's contention failed.

Final Conclusion: The dismissal of the Department's appeal was justified, and the finding against inclusion of such cost in the assessable value of the component parts was sustained.

Ratio Decidendi: A demand or valuation adjustment cannot be upheld on a ground not alleged in the show cause notice, and adjudication must remain confined to the case set out in the notice.

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