Zonal wholesale pricing can justify different buyer classes for assessable value where market conditions differ.

Wholesalers in different geographical zones may be treated as separate classes of buyers where the pricing structure is commercially justified by factors such as proximity to the factory, availability of comparable products, and prevailing market conditions. On that basis, a higher wholesale price charged in one zone cannot automatically be applied to sales in another zone for assessable value purposes. The note relies on prior Tribunal decisions supporting zonal price differentiation where the commercial basis for different prices is established.

---

---

Issues: Whether wholesalers in different geographical zones could be treated as different classes of buyers for the purpose of determining assessable value on the basis of different wholesale prices.

Analysis: The Tribunal noted that the price structure adopted by the assessee was based on the proximity of the factory area, availability of comparable products, and prevailing market conditions. It also relied on prior decisions holding that wholesalers in different regions may constitute different classes of buyers where the pricing pattern is commercially justified.

Conclusion: The zonal wholesalers were rightly treated as different classes of buyers, and the higher price charged in Zone A could not be applied to sales in Zone B for assessment purposes.

---