Transaction value under customs law cannot be rejected without reasons or reliable valuation basis.

Declared transaction value for imported goods cannot be rejected and replaced with an enhanced assessable value unless the assessing authority records reasons and identifies a lawful basis for doing so. The valuation scheme under section 14 of the Customs Act and the Customs Valuation Rules requires assessment on transaction value unless rejection is justified on permissible grounds; a vague reference to an unspecified international market value is insufficient. An enhancement made without reliable material or compliance with the statutory valuation framework is unsustainable, and the appeal succeeded.

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Issues: Whether the rejection of the declared transaction value and enhancement of assessable value for imported goods could be sustained in the absence of reasons or identifiable basis for valuation.

Analysis: The declared value of the imported plastic sheets was enhanced without recording any reason or disclosing any reliable basis for adopting a higher value. The governing valuation scheme requires assessment on transaction value unless rejection is justified on legally permissible grounds, and section 14 of the Customs Act and the Customs Valuation Rules do not permit a vague reference to an unspecified international market value. An assessment made without identifiable material and without compliance with the statutory valuation framework cannot be upheld.

Conclusion: The rejection of the transaction value and the enhanced assessment were not sustainable and the appeal succeeded.

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