Assessable value cannot include notional interest on purchaser advances absent proof that the advances depressed the goods' price.

Notional interest on advances received from a purchaser is not includible in the assessable value of goods merely because the advances remained with the seller for some time. Inclusion requires a finding that the advances depressed the price of the final product. On the stated facts, no such finding was recorded, and the attempt to distinguish the case by the period for which the advances were retained was held irrelevant, particularly for tailor-made goods. The addition was therefore set aside.

---

---

Issues: Whether notional interest on advances received from the purchaser was includible in the assessable value of the goods.

Analysis: The authorities had confirmed duty by adding notional interest on advances taken from the purchaser, but no finding was recorded that the advances had resulted in depression of the price of the final product. The distinction sought to be drawn on the basis of the period for which the advances remained with the appellant was held to be irrelevant on the facts, particularly where the goods were tailor-made and the earlier Tribunal decisions on similar advances were applicable.

Conclusion: Notional interest on the advances was not includible in the assessable value. The addition was set aside and the appeal was allowed.

Ratio Decidendi: Advances received from a purchaser do not form part of assessable value merely because they were retained for some time, unless it is shown that they depressed the price of the goods.

---