Transaction value under Customs Valuation Rules cannot be rejected without evidence, recorded reasons, and sequential use of valuation methods.

Declared transaction value of imported goods cannot be rejected and enhanced merely by referencing higher imports at another port unless the department supplies supporting documents, establishes comparability of the goods, and records valid reasons under the Customs Valuation Rules. The valuation hierarchy must also be followed sequentially before moving to a higher method of assessment. On the stated facts, the absence of documentary support for the Mumbai import value, the lack of clear proof that the goods were identical, and the failure to record specific reasons for rejecting transaction value made the enhancement unsustainable, so the declared value had to be accepted.

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Issues: Whether the declared transaction value of the imported goods could be rejected and the assessable value enhanced on the basis of imports at another port without furnishing documentary support, specifying valid reasons under the Customs Valuation Rules, and following the valuation rules sequentially.

Analysis: The assessment was enhanced on the footing that similar goods had been imported at Mumbai at a higher value, but no documentary evidence supporting that adopted value was supplied to the importer. The record also did not clearly establish that the goods imported at Mumbai were identical to the goods imported by the appellant. The reasons required for rejecting the transaction value under Rule 4(2) were not specifically recorded, and the valuation scheme was not followed in the required sequence before resorting to a higher method of valuation. The reliance on the absence of a manufacturer's invoice did not cure these defects.

Conclusion: The rejection of the declared value was unsustainable, and the transaction value was required to be accepted. The appeal was allowed and the impugned enhancement was set aside.

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