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Issues: Whether, for valuation of the goods manufactured by the respondent, the assessable value had to include the cost of the metal materials in addition to the grooving charges, and whether the Collector (Appeals) was right in excluding the material cost.
Analysis: The appeal was governed by the earlier view taken in the connected matter, where it was held that valuation under Rule 6(b)(ii) of the Central Excise (Valuation) Rules, 1975 required inclusion of both the cost of metal materials and the grooving charges. On that basis, the exclusion of the material cost from assessable value could not be sustained.
Conclusion: The assessable value had to include the cost of metal materials as well as grooving charges, and the Collector (Appeals)'s order excluding the material cost was unsustainable.
Final Conclusion: The departmental challenge succeeded and the original demand order was restored.
Ratio Decidendi: In valuation under Rule 6(b)(ii), the assessable value must reflect both the cost of the materials used and the manufacturing charges incurred in processing them.