Apportioned valuation of dies for printed pouches must spread tooling cost over expected output, not load one clearance.
Separate recovery of the cost of dies did not exclude their value from the assessable value of printed pouches, because the dies formed part of the manufacturing cost used to produce the goods. The valuation had to follow an apportionment method: the dies' cost could not be added in full on the first clearance or against a single lot, but had to be spread over the expected production and the anticipated life of the dies. The matter was remanded for fresh quantification on that apportioned basis.
Issues: Whether the cost of dies separately recovered from customers was includible in the assessable value of printed pouches, and whether such cost could be added in full at one go or had to be spread over the quantity of pouches manufactured with the dies.
Analysis: The separate recovery of the cost of dies did not alter the position that the dies were developed by the appellant for manufacture of the printed pouches and that their value was part of the manufacturing cost relevant to valuation. The earlier decision in the appellant's own case was followed, and the principle of apportionment was affirmed. The reasoning accepted that the value of the dies could not be loaded entirely on the first clearance or on one lot, because the dies had to be valued with reference to their expected life and the quantity of pouches manufactured using them. The Board's clarification on spreading the cost of patterns over anticipated production was treated as supporting the same valuation approach.
Conclusion: The cost of the dies was includible in the assessable value, but only by proportionate spread over the expected production of pouches, not by adding the entire cost in one go. The matter was remanded for fresh quantification and determination.
Final Conclusion: The appellant obtained relief on the method of valuation, with the matter sent back for recalculation of the assessable value on an apportioned basis.
Ratio Decidendi: Where dies or similar tooling are separately recovered but are used over a series of manufactured goods, their value must be apportioned over the anticipated output for valuation purposes and cannot be loaded wholly on a single lot of clearances.
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