Cash discount at variable rates may be admissible where records support the claim and no basis exists to reject the higher rate.

Cash discount may be allowed at different rates in the assessable value where the price lists and finalisation records support the assessee's claim. The evidence showed that discounts were extended at two rates, and the rejection of the higher rate lacked a sufficient basis. The record did not establish that the discount was confined only to advance payment. The separate issue of whether notional interest on advance payment could be added was not determined in these proceedings, as no finding was recorded on that point. Accordingly, the disallowance of the higher cash discount rate could not be sustained.

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Issues: Whether cash discount at two different rates was admissible in the assessable value, and whether any notional interest on advance payment could be added.

Analysis: The price lists and finalisation records showed that the assessee had produced evidence of discount being extended at two rates. Cash discount may be permissible at variable rates depending on the circumstances in which payment is made. The rejection of the higher rate was not supported by any sufficient basis, and the finding that the discount was confined to advance payment was not established. The separate contention regarding inclusion of notional interest on advance payment was not decided, as no finding was made on that aspect in these proceedings.

Conclusion: Cash discount at two different rates was admissible, and the disallowance of the higher rate could not be sustained.

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