Contract price valuation cannot be arbitrarily loaded with profit when unrelated parties disclose full particulars.

Where the contract price between unrelated parties was shown as the normal price and the price list disclosed complete valuation particulars, an additional 15% loading toward margin of profit was impermissible. The declared assessable value of the pre-stressed cement concrete poles was therefore accepted, and arbitrary enhancement for profit was rejected.

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Issues: Whether 15% addition towards margin of profit was justified while determining the assessable value of the pre-stressed cement concrete poles supplied under contract.

Analysis: The price declared by the assessee was found to be a contract price arrived at between parties not shown to be related persons. The price list furnished complete particulars of the charges and expenditure, and the declared value was treated as the normal price for purposes of valuation. In these circumstances, no basis was found for loading the declared price by an additional 15% towards profit.

Conclusion: The addition of 15% margin of profit was not warranted and the assessee's declared value was accepted.

Ratio Decidendi: Where the contract price between unrelated parties represents the normal price and the valuation particulars are fully disclosed, an arbitrary loading for margin of profit is impermissible.

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