Customs valuation requires proof before rejecting transaction value; comparable imports and price guides cannot replace a genuine invoice price.

Customs valuation must start from the declared transaction value, and that value cannot be rejected unless there is evidence that it is not genuine or correct. Where imported goods are mixed, heterogeneous floor sweepings and are not truly comparable from consignment to consignment, contemporaneous imports, Platt's prices and departmental standing orders cannot by themselves justify enhancement. The import contract was pre-registered and there was no proof of undervaluation or unreliability of the invoice price. On those facts, the declared invoice value had to be accepted and the proposed enhancement of assessable value was unsustainable.

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Issues: (i) whether the declared invoice price of imported floor sweepings could be rejected for purposes of customs valuation; (ii) whether contemporaneous imports, Platt's prices and departmental guidelines could lawfully be used to enhance value in the absence of doubt about the transaction value.

Issue (i): whether the declared invoice price of imported floor sweepings could be rejected for purposes of customs valuation

Analysis: The import contract was entered into in advance, registered with customs, and there was no evidence that the agreed price did not represent the genuine transaction value between the parties. The goods were mixed floor sweepings whose quantity and composition could vary from source to source and even from consignment to consignment, making comparison on the basis of a stated polymer predominance unreliable.

Conclusion: The declared invoice price could not be rejected, and the enhancement of value was not justified.

Issue (ii): whether contemporaneous imports, Platt's prices and departmental guidelines could lawfully be used to enhance value in the absence of doubt about the transaction value

Analysis: Resort to other valuation methods was impermissible unless the Revenue first established that the invoice price was not correct or genuine. In the present facts, contemporaneous imports were not a reliable basis because the goods were heterogeneous and non-comparable. Departmental standing orders and Platt's prices could not override the statutory valuation scheme or substitute for proof of undervaluation.

Conclusion: Contemporaneous imports, Platt's prices and departmental guidelines could not be used to enhance the assessable value on these facts.

Final Conclusion: The customs valuation enhancement was unsustainable, and the importers were entitled to relief with the benefit of acceptance of the declared value.

Ratio Decidendi: Customs valuation must proceed from rejection of the declared transaction value on evidence of its unreliability; in the absence of such proof, comparable imports, price guides or administrative standing orders cannot be used to substitute a genuine invoice price, especially where the goods are not truly comparable.

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