Assessable value excludes cardboard box packing cost where such packing was not necessary for factory-gate wholesale delivery.

Cardboard box packing costs for glucose biscuits were held deductible from assessable value because the boxes were used only for supply to up-country buyers, while factory-gate clearances to local wholesalers were made in polythene bags after wrapping in wax paper and printed paper. On these facts, cardboard boxing was not necessary for delivery in the wholesale market at the factory gate, so its cost was not part of the assessable value. The assessee was therefore entitled to the deduction.

---

---

Issues: Whether the cost of cardboard boxes used for packing glucose biscuits was includible in the assessable value.

Analysis: The biscuits were first wrapped in wax paper and printed paper. Cardboard boxes were used only when packets were supplied to up-country buyers, while glucose biscuits delivered at the factory gate to local wholesalers were packed in polythene bags. On these facts, the packing in cardboard boxes was not necessary for delivery in the wholesale market at the factory gate, and the deduction claimed for such packing cost was justified.

Conclusion: The cost of cardboard boxes was not includible in the assessable value, and the assessee was entitled to the deduction.

---