Assessable value excludes interest on commission-agent advances where no nexus to sale price or buyer consideration is proved.

Interest on advances received from commission agents was not includible in the assessable value of excisable goods because no material showed any additional consideration flowing from buyers. The commission agents were not the buyers, and no nexus was established between the interest earned on deposits and the sale price. As the receipt was not from customers and the basis for valuation inclusion was absent, the appeal succeeded.

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Issues: Whether interest on advances received from commission agents was includible in the assessable value of the excisable goods.

Analysis: The appellants sold goods through commission agents for wholesale transactions and received deposits from them, on which interest was paid. No material showed any flow of additional consideration from the buyers. The commission agents were not buyers, and no nexus was established between the interest and the sale price. The receipt of interest was also not from the customer, and the basis for inclusion in assessable value was therefore absent.

Conclusion: Interest on advances received from commission agents was not includible in the assessable value, and the appeal succeeded.

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