Assessable value excludes foundation erection costs where only the manufactured ingot buggy is the excisable product.

The assessable value of the ingot buggy for central excise included only the value of the excisable manufactured product, not the cost of bought-out items used for laying the foundation on which the buggy moved. The foundation was treated as immovable property, so expenses incurred for erecting it, or for items used in that post-manufacture activity, could not be added to the buggy's assessable value. On that basis, the Revenue's appeal failed.

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Issues: Whether the cost of bought-out items used for laying the foundation on which the ingot buggy moves was includible in the assessable value of the ingot buggy for central excise purposes.

Analysis: The ingot buggy was the excisable product and not the entire system comprising the buggy and the foundation. The foundation was treated as immovable property and not goods. Expenses incurred for erecting the foundation or for items used in that subsequent activity could not form part of the assessable value of the manufactured ingot buggy.

Conclusion: The cost of bought-out items used for laying the foundation was not includible in the assessable value of the ingot buggy, and the Revenue's appeal failed.

Ratio Decidendi: Only the value of the excisable manufactured product is includible in assessable value, and post-manufacture erection expenses relating to immovable foundation work are not part of that value.

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