2026-VIL-547-CESTAT-CHE-CE
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CENTRAL EXCISE CESTAT Cases

Central Excise - Valuation of aluminium die-cast components - Department included amortized cost of customer-supplied moulds and dies in assessable value - Whether amortized value of customer-supplied dies and moulds is includible in the assessable value of die-castings - HELD - The amortized value of dies and moulds supplied by customers or manufactured for customers and used in the manufacture of aluminium die-castings is includible in the assessable value of the finished goods. The statutory provisions under Section 4 of the Central Excise Act and Rule 6 of the Central Excise Valuation Rules clearly recognize that moulds and dies supplied by the buyer represent a form of additional consideration, and their value must be included in the assessable value of the goods manufactured using those moulds. Relying on the Larger Bench decision in Mutual Industries Ltd. and subsequent rulings, the Tribunal rejected the appellant's argument that including the amortized cost of moulds would amount to double taxation – The moulds and castings are distinct excisable goods and that payment of duty on moulds does not preclude inclusion of their amortized cost in the assessable value of the finished castings - The amortised value of dies and moulds supplied by customers or manufactured for customers and used in the manufacture of aluminium die-castings is includible in the assessable value of the finished goods - The appeal is partly allowed with the demand restricted to the normal period of limitation, and the penalty imposed on the appellant set aside
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