Customs valuation requires genuine comparability; declared import value of suitcases could not be rejected on a flawed earlier import comparison.

Declared transaction value of imported suitcases could not be rejected where the department relied on an earlier import as a supposed contemporaneous comparable, but the record showed material differences in style, design, size, quality of inputs, supplier and invoice particulars. The importer had also produced contemporaneous purchase order and manufacturer's invoice evidence matching the present transaction. On these facts, the department failed to establish that the compared imports were genuinely comparable in all material respects, so the declared value could not be displaced on the materials used for enhancement.

---

---

Issues: Whether the declared transaction value of the imported suitcases could be rejected and the goods revalued on the basis of an earlier import said to be contemporaneous and identical.

Analysis: The authorities proceeded on the footing that the earlier and present consignments were identical and comparable, but the record showed material differences in style, design, size, quality of inputs, supplier, and invoice particulars. The importer had placed contemporaneous documents on record showing that the present purchase order and manufacturer's invoice tallied, while the comparative exercise made by the department overlooked the specific differences pointed out in reply to the show cause notice. In these circumstances, the basis for rejecting the declared value was not made out, and the earlier import could not be treated as a reliable comparable for valuation.

Conclusion: The rejection of the transaction value was unsustainable and the declared value could not be displaced on the materials relied upon by the department.

Ratio Decidendi: Where the department seeks to reject declared value under customs valuation law, it must establish that the compared imports are genuinely comparable in all material respects; material differences in goods, quality, design, supplier, and supporting documents defeat reliance on the earlier import as a basis for enhancement.

---