Customs valuation requires acceptance of declared transaction value unless reliable comparable identical goods justify rejection.

Customs valuation of imported fabrics must ordinarily proceed on the declared transaction value unless the Revenue shows special circumstances and produces reliable comparable identical goods. Here, the comparison imports were not identical, as they differed in description, width, weight and other import particulars. In the absence of such valid comparables, the declared value could not be rejected and the proposed enhancement of assessable value could not be sustained. The operative principle is that transaction value remains binding unless the statutory basis for departure is established on dependable evidence.

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Issues: Whether the declared transaction value of the imported fabrics could be rejected and the assessable value enhanced on the basis of the Revenue's comparison imports.

Analysis: The imported fabrics were found not to be identical to the relied-upon comparison goods because of differences in description, width, weight and surrounding import particulars. No special circumstances justifying departure from the declared transaction value were shown. In the absence of comparable identical goods at higher values, the declared value could not be discarded and the enhancement could not be sustained.

Conclusion: The transaction value was rightly accepted and the enhancement of assessable value was unsustainable.

Ratio Decidendi: In customs valuation, the declared transaction value must be accepted unless the Revenue establishes special circumstances and reliable comparable identical goods warranting rejection of that value.

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