Assessable value excludes bought out accessories when not manufactured into the cleared product, despite joint supply or invoicing.

Bought out circlips supplied with pistons and gudgeon pins were held not includible in the assessable value of the piston assembly because they were not fitted or manufactured as part of the cleared product. Their supply together with the main goods, or under a single invoice, did not by itself make them part of the manufactured assembly. The items were general-purpose fastening devices available in the market, were not always supplied with the pistons and gudgeon pins, and could be declined by the buyer in some clearances. On those facts, they were treated as accessories rather than essential components, and the exclusion of their value was sustained.

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Issues: Whether the value of bought out circlips supplied along with pistons and gudgeon pins was includible in the assessable value of the piston assembly.

Analysis: The test of essentiality was not accepted as decisive, and the fact that the items were packed together or supplied under a single invoice did not by itself make the circlips part of the manufactured sub-assembly. The circlips were bought out items, not always supplied with the pistons and gudgeon pins, and in some clearances the buyer had the option not to purchase them. They were general purpose fastening devices available in the market and were not fitted or subjected to any manufacturing process before clearance. On these facts, the circlips were treated as accessories rather than essential components of the piston assembly.

Conclusion: The value of the circlips was not includible in the assessable value of the piston assembly, and the revenue's appeal failed.

Final Conclusion: The impugned order excluding the value of the bought out circlips was sustained, and the departmental challenge was rejected.

Ratio Decidendi: Bought out items that are not fitted or manufactured as part of the cleared product do not become includible in assessable value merely because they are supplied along with the manufactured goods or are said to be functionally useful.

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