Transaction value in import valuation must be accepted unless cogent reasons justify rejection and revaluation under the valuation rules.

Declared import value can be rejected only where cogent reasons bring the case within the recognised exceptions to the transaction-value rule. Reliance on a valuation circular and depreciation alone was insufficient, because the show-cause notice did not set out a satisfactory basis for discarding the value declared at import or for excluding Rule 4(1) treatment under Rule 4(2). Without a properly reasoned case and a meaningful opportunity to rebut it, revaluation of the goods could not be sustained, and the declared transaction value was required to be accepted.

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Issues: Whether the declared value of imported goods could be discarded and the goods revalued on the basis of depreciation under the valuation circular, or whether the declared transaction value was required to be accepted.

Analysis: The declared price could be rejected only if cogent reasons existed to bring the case within the exceptions to the transaction-value rule. The show-cause notice relied on the valuation circular and depreciation, but did not disclose any satisfactory basis for discarding the value declared at import. In the absence of reasons justifying exclusion of Rule 4(1) treatment under Rule 4(2), and without affording a meaningful opportunity to rebut a properly reasoned case, the proposed revaluation could not be sustained.

Conclusion: The declared value had to be accepted as the transaction value, and the appellant succeeded.

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