Transaction value of imported goods cannot be rejected on an incomparable smaller import; bulk contract claims need factual verification.

Declared transaction value of imported synthetic camphor could not be rejected merely by reference to a much smaller contemporaneous import, because such a comparison was not a proper benchmark for a substantially larger bulk consignment. The importer's claim of bulk purchase, however, required verification from invoices and letters of credit to confirm that the contracted quantity was actually imported. The enhancement of value was therefore set aside and the matter remanded for de novo examination after verification of the bulk-import documents.

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Issues: Whether the declared transaction value of imported synthetic camphor could be rejected and enhanced on the basis of a contemporaneous import of a much smaller quantity, and whether the matter required remand for verification of the alleged bulk contract and supporting import documents.

Analysis: The quantity relied upon by the department for comparison was 14 MTs, whereas the appellant's declared import was for 84 MTs. Such a small import was not a proper benchmark for valuing a substantially larger bulk consignment. At the same time, the appellant's claim of bulk purchase required verification through the relevant invoices and letters of credit to establish that the contracted quantity was actually imported. Since subsequent imports of the same goods had also been accepted at a higher but still lower value, the matter needed fresh examination by the original authority.

Conclusion: The enhancement of value was set aside and the matter was remanded for de novo consideration after verification of the bulk-import documents.

Ratio Decidendi: Declared transaction value cannot be rejected merely on the basis of an incomparable smaller import, and where bulk-import claims require factual verification, the proper course is remand for fresh determination.

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