Declared transaction value can be rejected where contemporaneous import data and comparable invoices support a higher assessable value.

Declared transaction value for imported soap may be rejected when contemporaneous import data and comparable supplier invoices support a higher assessable value. The comparison with an earlier invoice from the same overseas supplier, together with bill of entry particulars for similar imports and comparable soaps from China, was treated as reliable evidence of value. The importer's explanation that the earlier invoice was about one year old, and the absence of any written contract or credible contemporaneous proof of the lower price, were insufficient to rebut that evidence. On that basis, the enhancement of assessable value was upheld and the appeal was rejected.

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Issues: Whether the declared assessable value of imported soap could be rejected and enhanced on the basis of an earlier invoice of the same overseas supplier and contemporaneous import data.

Analysis: The declared price was compared with an earlier invoice issued by the same manufacturer showing a higher price, and the explanation that the invoice was about one year old was found insufficient to dislodge the evidentiary value of that comparison. The authority also relied on other bill of entry particulars of more contemporaneous imports of the same brand and other comparable soaps from China at the same price level. The importer did not establish any written contract for the lower price or produce convincing evidence to show that the lower declared value reflected the real transaction value.

Conclusion: The enhancement of assessable value was upheld and the appeal was rejected.

Ratio Decidendi: Where contemporaneous import evidence and comparable supplier data support a higher value, the declared transaction value may be rejected unless the importer rebuts that evidence with credible and contemporaneous proof of the lower price.

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