Normal packing cost forms part of assessable value when it is necessary for marketability and safe transport of goods.

The cost of cardboard packing used for up-country sales of biscuits was held to form part of the assessable value because the packing was normal and necessary for marketability and safe transport, not an optional extra. The cardboard boxes contained the biscuit packets and were the usual packing for those sales, so the packing expense could not be deducted from value. The demand to exclude the packing cost was therefore rejected.

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Issues: Whether the cost of cardboard packing used for up-country sales of biscuits could be excluded from the assessable value.

Analysis: The packing was not an optional or extra expense but was required to preserve the biscuits during transport and sale in up-country areas. The cardboard boxes contained the biscuit packets and constituted the usual packing for those sales. On that footing, the packing cost formed part of the value of the goods and could not be deducted.

Conclusion: The cost of the cardboard packing was not deductible from the assessable value, and the demand to exclude it was rejected.

Ratio Decidendi: Where packing is the normal and necessary packing for marketability or safe transport of the goods, its cost forms part of the assessable value and is not excludable.

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