Secondary packing deduction for assessable value allowed where wooden boxes were used only for distant transport protection.

Wooden boxes used only as secondary packing for carbon paper sent to distant centres were deductible from assessable value because the goods were already cleared in kraft paper and gunny bags, and the additional wooden packing was not shown to be necessary for wholesale trade at the factory gate. The evidence indicated that such boxes were used solely to safeguard consignments during longer transport, while Ahmedabad clearances were made without them. The refusal to allow deduction was therefore erroneous.

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Issues: Whether the cost of wooden boxes used as secondary packing for carbon paper cleared to distant centres was deductible from assessable value.

Analysis: The goods were first packed in kraft paper and gunny bags, and only consignments sent to centres other than Ahmedabad were additionally packed in wooden boxes. Since the Ahmedabad clearances were made without wooden boxes, such additional packing was not shown to be necessary for wholesale trade at the factory gate. The evidence therefore supported the claim that the wooden boxes were used only for safeguarding goods during distant transport.

Conclusion: The cost of wooden boxes was deductible, and the refusal to allow the deduction was erroneous.

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