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    <title>1977 (1) TMI 45 - HIGH COURT OF JUDICATURE AT ALLAHABAD</title>
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    <description>Under the unamended Section 4 of the Central Excises and Salt Act, the assessable value for central excise was to be based on the wholesale cash price at removal, with only manufacturing cost and manufacturing profit treated as relevant. Packing dry cell batteries in cartons and wooden cases was characterised as a post-manufacturing step done for convenience, protection and transport, not as part of manufacture. The text also notes that, where a taxing provision admits two reasonable constructions, the interpretation favourable to the subject should be preferred. On that basis, packing charges were treated as outside assessable value and the resulting additional excise demand was regarded as unsustainable.</description>
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    <pubDate>Mon, 31 Jan 1977 00:00:00 +0530</pubDate>
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      <title>1977 (1) TMI 45 - HIGH COURT OF JUDICATURE AT ALLAHABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=40629</link>
      <description>Under the unamended Section 4 of the Central Excises and Salt Act, the assessable value for central excise was to be based on the wholesale cash price at removal, with only manufacturing cost and manufacturing profit treated as relevant. Packing dry cell batteries in cartons and wooden cases was characterised as a post-manufacturing step done for convenience, protection and transport, not as part of manufacture. The text also notes that, where a taxing provision admits two reasonable constructions, the interpretation favourable to the subject should be preferred. On that basis, packing charges were treated as outside assessable value and the resulting additional excise demand was regarded as unsustainable.</description>
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      <pubDate>Mon, 31 Jan 1977 00:00:00 +0530</pubDate>
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