Customs valuation: declared transaction value stands unless contemporaneous comparable imports or concrete proof show the invoice price is incorrect.

Declared transaction value cannot be rejected for customs valuation merely because another import appears higher; the authority must show contemporaneous imports of identical or similar goods or other concrete proof that the invoice price is incorrect. An older invoice, a different grade of goods, or the absence of reasons in the invoice for the agreed price is not enough to displace the declared value without proof of false pricing. On that basis, pro rata enhancement of the remaining grades also failed because it depended on the same unsupported rejection of the declared value.

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Issues: Whether the declared import value could be rejected and the assessable value enhanced on the basis of alleged comparable imports, and whether pro rata enhancement of the remaining grades was justified.

Analysis: The enhancement was not sustainable because no contemporaneous import of identical or similar goods was shown, the reliance placed on an older invoice and on another grade was not supported by any proved basis of equivalence, and the manufacturer's invoice was discarded without concrete evidence of incorrect pricing. The invoice did not require reasons to be stated for the agreed price, and the record did not establish that the transaction value was false. Since the foundation for rejecting the declared value failed, there was also no justification for enhancing other grades on a pro rata basis.

Conclusion: The declared value was accepted and the enhancement of assessable value was set aside in favour of the assessee.

Ratio Decidendi: In the absence of contemporaneous import evidence or concrete proof that the invoice value is incorrect, the declared transaction value cannot be rejected merely because another import appears higher or because the invoice does not explain the pricing.

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