Valuation of captively consumed goods may follow final product profit margin when no separate market price exists.

Where captively consumed laminations were not separately marketable and no independent sale price was available, the assessable value could be based on the profit margin of the corresponding final product. The lower authorities applied that approach because no material showed that such an adjustment was impermissible or that the notional profit margin on the laminations had to be lower than the final product's actual profit. The valuation method was therefore upheld for the intermediate goods.

---

---

Issues: Whether, in the absence of marketability and sale price of the captively consumed laminations, the profit margin of the corresponding final product could be adopted for determining the assessable value of the intermediate goods.

Analysis: The laminations were not marketable as such and no separate sale price could be determined. In these circumstances, the lower authorities treated the profit margin of the final product as the profit margin of the captively consumed goods. No material was produced to show that such adjustment was impermissible or that the notional profit margin on the laminations would necessarily be less than the actual profit of the final product.

Conclusion: The adoption of the final product's profit margin for valuation of the captively consumed laminations was upheld.

Ratio Decidendi: Where captively consumed goods are not separately marketable and no better material is available, the profit margin of the corresponding final product may be adopted for determining their assessable value.

---