Mould development charges enter assessable value only when linked to actual manufacture; unverified demands cannot stand.

Mould development or master die charges are includible in the assessable value of glass bottles only when they relate to moulds actually utilised in manufacturing the final excisable goods. Where no resultant product came into existence, or no charges were raised for rejected moulds, those amounts could not be added without factual verification. The record required a proper linkage between debit notes and actual production, but the departmental authorities failed to make that verification before rejecting the claim. The demand was therefore unsustainable on the existing record, and the matter had to be remanded for de novo consideration.

---

---

Issues: Whether mould development charges were includible in the assessable value of glass bottles where the moulds were not utilised for manufacture or no resultant product came into existence, and whether the matter required remand for proper verification.

Analysis: The liability to add mould or master die costs depends on their actual utilisation in the manufacture of the final product. The record showed the assessee's case that charges were included where bottles were manufactured, while no charges were raised or collected for rejected moulds on which no production resulted. The departmental authorities did not carry out a proper verification linking debit notes with resultant manufacture and instead rejected the claim mainly for want of further evidence. The Tribunal held that such linkage was necessary before confirming any demand, because charges relating to moulds on which no goods were manufactured could not be brought into the assessable value.

Conclusion: The demand could not be sustained without proper verification, and the matter was required to be remanded to the original authority for de novo consideration.

Ratio Decidendi: Mould development or master die charges are includible in assessable value only to the extent they relate to moulds actually utilised for manufacture of the final excisable goods; charges for unutilised moulds or rejected work cannot be added without factual verification linking them to resultant production.

---