Job-work valuation: no separate profit loading was required where labour charges already included the profit element.

In valuing goods cleared on job work basis, no separate addition for margin of profit was required where the disclosed labour charges already included that element. The dispute was limited to whether assessable value could be increased by a further 10% profit addition; the appellate authority accepted the assessee's position that profit was embedded in the labour charges. The Tribunal found no basis on the record to disturb that finding, so the Revenue's challenge failed.

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Issues: Whether, in valuing the goods cleared on job work basis, any further addition towards margin of profit was required when the declared labour charges were found to include such profit element.

Analysis: The respondents had disclosed the cost of raw material and labour charges, and the dispute was confined to whether a separate addition of 10% margin of profit could be made in the assessable value. The appellate authority had accepted the respondents' contention that the labour charges already included the profit element. On the record before it, the Tribunal found no reason to differ from that view.

Conclusion: No further addition towards margin of profit was required, and the Revenue's challenge failed.

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