Transaction value of second-hand machinery cannot be rejected without proof of undervaluation or contemporaneous imports.

Declared transaction value of imported second-hand machinery cannot be rejected merely because the goods are old or the age is disputed. The Revenue must produce independent evidence of undervaluation or contemporaneous imports before enhancing value. In the absence of such material, age-related deduction or reassessment does not justify displacement of the invoice value. The stated principle is that the burden remains on the Revenue to prove grounds for rejection of transaction value, and where no contemporaneous import data or other evidence of undervaluation is shown, the declared value must be accepted.

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Issues: Whether the declared transaction value of second-hand imported machinery could be rejected and the value enhanced in the absence of evidence of undervaluation or contemporaneous imports.

Analysis: The appeal concerned valuation of second-hand machinery imported under declared invoice values. The authorities enhanced value on the basis of age-related deduction and rejected the declared value, but no independent evidence of undervaluation was produced. In such a situation, the burden remained on the Revenue to justify rejection of transaction value. The reasoning applied the settled principle that, absent evidence of contemporaneous import or other material showing undervaluation, declared transaction value cannot be displaced merely because the goods are second-hand or their age has been misdeclared.

Conclusion: The rejection of the transaction value was held to be unsustainable and the appeal was allowed.

Ratio Decidendi: Where no evidence of undervaluation or contemporaneous import is shown, the declared transaction value of imported second-hand machinery must be accepted and cannot be rejected merely on the basis of age-related reassessment.

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