Full Judgment
2. The assessee's contention of not adding the cost of the roller cannot be accepted since that issue is settled by the Larger Bench (see Mutual Industries Ltd. v. CCE . The amortized costs are to be added. If the Revenue is contesting the amortization arrived at by the assessee, they could have got the same determined under the provisions of Section 14A of the Central Excise Act, 1944 by deputing their Cost Accountant instead of resorting to the loading of full value of sale. We cannot uphold such loading.
3. Both sides agree that Cost Accounts/Auditors services could be availed in this case and matter could be redetermined. We agree. The department should depute their own Cost Auditor to get the needful done since the assessee is a small scale unit and has pleaded the high costs of getting Cost Audits done on their own. After obtaining the report of the Assistant Director (Costs) of the Department, a copy of thereof be supplied to the assessee and values and duties be redetermined after hearing the assessee.