Normal packing principle bars deduction for corrugated box packing used in wholesale sale of talcum powder.

Secondary packing in corrugated boxes used for talcum powder was treated as part of the normal wholesale package, not as an excludable protective expense from assessable value. Because the goods were sold to wholesale buyers at the factory gate and corrugated boxes containing several tins were customary in wholesale trade, the cited principle on normal packing and assessable value applied. No distinguishing feature was shown to remove the case from that rule, so deduction for the corrugated box packing was not allowable.

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Issues: Whether the cost of corrugated boxes used as secondary packing for talcum powder could be deducted from the assessable value on the ground that such packing was only for protection and not for making the goods marketable.

Analysis: The goods were sold to wholesale buyers and not in retail at the factory gate. In wholesale trade, packing in corrugated boxes containing several tins constituted the normal package. The cited authorities on normal packing and assessable value were applied, and no distinguishing feature was shown to take the case outside that principle.

Conclusion: The deduction towards corrugated box packing was not allowable and the denial of deduction was upheld.

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