Assessable value based on genuine contract price, not buyer's later resale price, where manufacturer sold under an independent contract.

Assessable value was to be determined on the contract price between the manufacturer and its immediate buyer where that transaction was genuine and supported by the filed price list and purchase order. Direct delivery to the buyer's customer did not justify substituting the buyer's subsequent resale price. The buyer's status as a trader, and the fact that the end recipient was a wholesale purchaser, was irrelevant when the manufacturer had sold under an independent contract to the immediate buyer. The assessable value therefore had to follow the declared contract price after usual deductions, not the higher resale price.

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Issues: Whether the assessable value of the goods was to be fixed on the contract price between the manufacturer and its immediate buyer, or on the higher price at which the buyer subsequently sold the goods to another purchaser.

Analysis: The price list was filed along with the purchase order of the immediate buyer, and the genuineness of that transaction was not doubted. The goods were sold to that buyer and payment was made by it. Mere direct delivery to the buyer's customer did not justify ignoring the contract price. The subsequent resale price of the buyer, or the fact that the buyer was a trader and the end recipient was a wholesale buyer, was held to be irrelevant for fixing assessable value where the manufacturer had sold the goods under an independent contract to the immediate buyer.

Conclusion: The assessable value had to be based on the contract price declared by the manufacturer after usual deductions, and not on the buyer's subsequent resale price.

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