Valuation of used machinery may rely on a comparable machine price with depreciation where exact market data is unavailable

For imported used and second-hand machinery, assessable value may be determined on a reasonable comparable price basis, with depreciation reflecting age and condition where no exact market price for the identical machine is available. Exact identity of the comparable model is not essential if direct price data for the used equipment is lacking, because valuation must proceed on practical evidence rather than rigid matching. On that approach, the departmental valuation based on the price of a similar machine, adjusted for years of use, was upheld and the challenge to valuation failed.

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Issues: Whether the assessable value of the imported used sonograph was correctly determined on the basis of the price of a new comparable machine after allowing depreciation.

Analysis: In the case of used and second-hand machinery, a direct price list of the exact machine is often unavailable, and valuation must be made on a reasonable basis having regard to the condition of the machine at the time of import and other relevant evidence. The machine was shown to have been purchased in 1984, and the Department relied on the price list of a similar scanner at US $ 18,700, thereafter granting depreciation for years of use and arriving at Rs. 1,38,000/-. The contention that the model was not identical was not accepted, because valuation of second-hand machinery necessarily proceeds on a practical comparison and exact identity is seldom available.

Conclusion: The assessable value fixed by the Department was upheld and the challenge to valuation failed.

Final Conclusion: The appeal did not succeed, and the departmental valuation of the imported used equipment stood affirmed.

Ratio Decidendi: Valuation of used and second-hand machinery may be based on a reasonable comparable price with appropriate depreciation where no exact market price for the identical machine is available.

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