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Issues: Whether interest on advances received from buyers was liable to be added to the assessable value of the castings.
Analysis: The price structure showed that the charged price already included development charges and the advance was comparatively insignificant. There was no reliable material to establish a nexus between the advances and the price charged, and the goods were manufactured to buyer specifications rather than for general sale. On these facts, the element of interest on the advances was not shown to form part of the assessable value.
Conclusion: The addition of interest on advances to the assessable value was not justified and the assessee succeeded on the issue.