Customs valuation of imported camphor must follow comparable imports and the lowest available value, not unsupported enhancement.

Contemporaneous imports of like camphor from the same country of origin had been assessed at broadly comparable values, and an earlier import of the same product had also been accepted at the declared value. In that setting, the customs valuation had to follow the comparable-import method, with Rule 5(3) requiring adoption of the lowest available comparable value. The declared transaction value was therefore not shown to warrant enhancement, and the assessed value was rightly left unchanged in favour of the importer.

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Issues: Whether the enhancement of assessable value of the imported camphor was justified, or whether the declared transaction value was liable to be accepted under the customs valuation rules.

Analysis: Similar goods imported from the same country of origin during the relevant period had been assessed at values broadly ranging from US$ 1100 to US$ 2030 per metric tonne, and a prior import of the same product from the same origin had also been assessed on acceptance of the declared value. In such circumstances, the valuation exercise had to proceed on the basis of comparable imports, and Rule 5(3) required adoption of the lowest value from the available comparable data. The declared transaction value was therefore not shown to be liable for enhancement.

Conclusion: The enhancement of assessable value was not justified and the declared value was rightly accepted, in favour of the assessee.

Final Conclusion: The appellate order setting aside the loading of value was sustained, and the challenge to that determination failed.

Ratio Decidendi: Where contemporaneous imports of like goods from the same country show a range of comparable values, the valuation must be based on the applicable comparable method and the lowest comparable value, rather than an unsubstantiated enhancement of the declared transaction value.

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