Consolidated import valuation for machinery and recommended spares upheld; separate assessment of accessories was unwarranted.

Where import documents show a consolidated price for machinery together with accompanying spares and accessories, separate assessment of the spare parts is not warranted. The final invoice and proforma invoice reflected a single consolidated value for the machinery import, and the earlier proforma invoice described the spares as recommended spare parts intended to accompany the machine. On those facts, the consolidated invoice value could be adopted for assessment and the authorities were not justified in treating the spare parts as separately assessable.

---

---

Issues: Whether the imported machine and its spare parts and accessories were required to be assessed separately, or whether the consolidated invoice value for the machine and associated spares and accessories could be adopted for assessment.

Analysis: The final invoice and the accompanying proforma invoice covered the import in question and reflected a consolidated price for the machinery. The earlier proforma invoice relied upon by the Revenue described the spare parts as recommended spare parts, which supported the view that the spares were intended to accompany the machine. On these facts, the case fell within a consolidated supply of machinery together with spares and accessories, and the basis for insisting on separate assessment was not made out.

Conclusion: The authorities were not justified in treating the spare parts as separately assessable or in rejecting the consolidated invoice value. The issue is decided in favour of the appellant.

Ratio Decidendi: Where the import documents show a consolidated price for machinery and accompanying spares and accessories, and the spares are shown as recommended for supply with the machine, separate assessment of those items is not warranted.

---