Secondary packing cost excluded from assessable value where goods were packed in wooden boxes for clearance.

The assessable value of excisable goods does not include the cost of secondary packing where wooden boxes or wooden crates are used for packing the cleared goods. Applying the governing precedent, the Tribunal treated such secondary packing as outside assessable value even though the goods were packed in wooden boxes in all cases. The legal effect is that the cost of the wooden boxes or wooden crates is excluded from valuation for excise purposes.

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Issues: Whether the cost of secondary packing in wooden boxes or wooden crates was includible in the assessable value of the goods cleared by the appellants.

Analysis: The dispute turned on whether wooden boxes or crates used as secondary packing formed part of the assessable value. Reliance was placed on the principle that the cost of such secondary packing is not includible in assessable value, even where the goods are packed in wooden boxes in all cases. Following the governing precedent, the Tribunal treated the cost of wooden boxes or wooden crates as outside the assessable value of the manufactured goods.

Conclusion: The cost of wooden boxes or wooden crates was held not includible in the assessable value, and the appellants succeeded.

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