Assessable value excludes bought-out accessories not proved integral to manufactured goods, as mere assertion cannot justify inclusion.

Bought-out electric motors, V-belt drives and geared motors used with rotary feeders and bag filters were not includible in the assessable value of the manufactured goods because they were not shown to be integral parts of the equipment. The factual record indicated that in many instances the accessories were sent directly to the customer's site without being brought into the factory, and no evidence established that the manufactured goods were incomplete without them. Mere assertion by the Revenue was insufficient to justify inclusion of their value in assessable value, so the revenue challenge failed.

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Issues: Whether the value of bought-out electric motors, V-belt drives, and geared motors used with Rotary Feeders and Bag Filters was includible in the assessable value of the manufactured goods.

Analysis: The bought-out items were not shown to be integral parts of the Rotary Feeders and Bag Filters. The factual record indicated that in many cases the accessories were sent directly to the customer's site without being brought to the factory, and no evidence was produced to establish that the goods manufactured by the respondent were incomplete without them. Mere assertion by the Revenue was held insufficient to prove includibility of their value in the assessable value.

Conclusion: The value of the bought-out items was not includible in the assessable value of the manufactured goods, and the Revenue's appeal failed.

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