Equalised freight and average discount are deductible from assessable value when based on uniform pricing and actual commercial allowances.

Equalised freight was deductible from assessable value where goods were sold at a uniform all-India price and transportation cost was genuinely incurred across sales; the existence of some factory-gate sales did not by itself defeat the deduction. Average discount was also deductible where it was computed from actual discounts allowed to different buyers at varying rates, because non-uniform discount rates did not make the deduction invalid when the method reflected the real commercial incidence passed on to customers.

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Issues: (i) Whether equalised freight was deductible from the assessable value where the goods were sold at a uniform all-India price, and (ii) whether average discount calculated on the basis of actual discounts allowed at different rates was deductible from the assessable value.

Issue (i): Whether equalised freight was deductible from the assessable value where the goods were sold at a uniform all-India price.

Analysis: The sales were made at a fixed uniform price irrespective of destination, and the mere fact that some factory-gate sales existed did not displace the admissibility of average freight deduction. The settled principle recognised by the Supreme Court permits deduction of average freight where the pricing structure is uniform and transportation cost is genuinely incurred across sales.

Conclusion: The deduction on account of equalised freight was admissible and the issue was decided in favour of the assessee.

Issue (ii): Whether average discount calculated on the basis of actual discounts allowed at different rates was deductible from the assessable value.

Analysis: The discounts were in fact granted to different buyers at varying rates depending on commercial considerations, and non-uniformity of discount did not by itself justify disallowance. Since the average discount was worked out from the actual discounts granted, the method adopted reflected the real quantum of discount actually passed on to customers.

Conclusion: The deduction for average discount was allowable and the issue was decided in favour of the assessee.

Final Conclusion: The appeal succeeded and the assessee was held entitled to deductions for both equalised freight and average discount in computing the assessable value.

Ratio Decidendi: Where sales are effected at a uniform price and the deductions claimed represent the actual commercial incidence of freight and discount, equalised freight and average discount based on actual allowances are deductible from assessable value.

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