Customs valuation must follow the sequential rules; a stray import with material differences cannot justify enhancement.

Declared import value may be rejected only if the Customs Valuation Rules are applied in their prescribed sequence, and any alternative benchmark must be based on reliable comparable imports. A single stray import with different country of origin, quantity and import circumstances could not justify enhancement, and the absence of contemporaneous, materially similar goods made Rules 5 and 6 inapplicable. Evidence of multiple clearances at comparable or lower prices, together with correspondence showing a negotiated price, also supported acceptance of the declared value. On these facts, the assessable value could not be enhanced.

---

---

Issues: Whether the declared transaction value of the imported goods could be rejected and enhanced on the basis of a stray import, and whether the valuation had to proceed sequentially under the Customs Valuation Rules before resorting to any alternative method.

Analysis: The appellate authority found that once the invoice value was rejected, the valuation machinery had to be applied in the prescribed sequence. Rules 5 and 6 governing identical and similar goods could not be invoked because the relied-upon import differed materially in country of origin, quantity, and circumstances of import. The single comparable import was not contemporaneous in the relevant sense, and the disparity in quantity made it unsafe to use as a benchmark. The authority further found that the Department had not rebutted the evidence of multiple clearances at comparable or lower prices, nor the correspondence showing a negotiated price. The Tribunal agreed that the Revenue had produced no material to displace these findings and that the declared value was properly accepted.

Conclusion: The enhancement of assessable value was not justified, and the Revenue's appeal failed.

Ratio Decidendi: Rejection of declared import value must be supported by application of the prescribed sequential valuation rules and by reliable comparable imports of materially similar goods in comparable quantity and circumstances; a stray import with material differences cannot sustain enhancement.

---