Archana Wadhwa, Member (J) - (1.)THE appellants are the job workers of Wipro Limited. Wipro supplied all the raw materials and packing materials and the appellants manufactured soap and cleared the same on payment of duty. THE appellants filed price lists from time to time supported by CA's Certificate for the cost of production and after including the job charges (which also included the job workers' profit), arrived at the assessable value.
(2.)A number of show cause notices were issued to the appellants seeking to include the following further costs in the assessable value declared by the appellants in the PLs :-
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During the adjudication proceedings, the ld. Assistant Commissioner accepted the submissions of the Appellants that octroi only on soap noodles supplied by Wipro is includible (as rest of the items were supplied locally from Mumbai itself and no octroi is paid on them), and since the goods are not insured no cost was incurred on insurance. Accordingly, the demands on both these accounts were dropped.

(3.)AS regards wastage and trader's profit, the appellants submitted that :-
(a) the wastage to the extent permissible by Wipro has already been included in the cost calculations given by them and the CA's Certificate clearly shows that such costs have been included;

(b) trader's profit is not includible in the assessable value in terms of the judgment of the Hon'ble Supreme Court in the case of Ujagar Prints.