1997 (4) TMI 158

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....each bullet made up of Rs. 1,07,000/- as fabrication cost and Rs. 48,400/- as the material cost for BQ steel plates. The price list was approved and duty was paid on that basis by the appellants. Subsequently it was found that the appellants had also received certain parts required for the bullets required for being tested and fitted to the bullets, the cost whereof had not been included in the declared assessable value. Show cause notice dated 8-10-1985 was issued by the Superintendent proposing demand of duty after increasing the cost of steel plates including the cost of fittings and adding notional margin of profit of 10% at the hands of the customers, IOC. The notice was followed by a corrigendum dated 22-6-1987 issued by the Collector....

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....nstituted component parts of the bullets and their value was rightly included in the assessable value of the goods in question. On the alternative plea raised in support of the appeal on the question of limitation, he had no comments to offer. 4. We have considered the submissions of both the sides. We have perused the record. We notice that the contract provides that necessary LPG tank wagon fittings for Dome and Barrel would be supplied free of cost by IOC which will be fitted and tested as per required specifications prior to installation and also after installation on tank wagons. It was clarified by the learned counsel that after such fitting and testing in the factory, these fittings are removed from the bullets and despatched....