Assessable value of packed goods includes necessary packing and handling costs, while transport deduction fails without proof of the charge split.
Packing necessary for wholesale delivery at the factory gate formed part of assessable value, so the cost of crates used for safe transport and the handling charges incurred within the factory were includible. Forwarding charges could be deducted only to the extent they truly represented transport from the factory gate to the customers' premises, but no material was produced to identify the actual transport component in the consolidated invoice amount. In the absence of proof of the split-up, no deduction was allowed and the assessee's relief on that issue failed.
Issues: Whether the cost of packing and handling charges formed part of the assessable value, and whether forwarding charges claimed as transport charges from the factory gate to the customers' premises were deductible in the absence of evidence showing the actual split-up of the consolidated invoice amount.
Analysis: The goods were big machines packed in crates for safe transport and delivery, and such packing was necessary for delivery in wholesale trade at the factory gate; its cost therefore had to be included in the assessable value. Handling charges incurred within the factory premises were also includible. Forwarding charges, if truly representing transport from the factory gate to the customers' premises, would be deductible, but no statement or other material was produced to establish the exact transport component in the consolidated invoice charges. The failure to assist in determining the actual or approximate transport charges meant that no relief could be granted.
Conclusion: The packing and handling charges were correctly included in the assessable value, and the claimed transport deduction was not allowed for want of proof.
Final Conclusion: The appeal failed and the refund relief granted by the lower authority, as modified by inclusion of the disputed charges, was not disturbed in the assessee's favour.
Ratio Decidendi: Where packing is necessary for wholesale delivery at the factory gate and the assessee fails to prove the transport component of consolidated charges, the packing and handling costs are includible in assessable value and no deduction for forwarding charges can be allowed.
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