Declared transaction value cannot be rejected without recorded reasons; unreliable market inquiry and non-comparable goods cannot justify valuation enhancement.

Declared transaction value under the customs valuation regime cannot be rejected unless the statutory conditions for discard are satisfied and legally sustainable reasons are recorded. In this matter, the invoice value of imported swimming goggles was accepted because no valid reasons were recorded to treat it as unacceptable, and the market inquiry was found unreliable: identical goods were not shown to be available, comparison was made with Chinese-origin items despite Taiwan origin imports, and no basis was explained for converting retail prices into CIF value. The enhancement of assessable value was therefore unjustified and the declared transaction value was required to be accepted.

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Issues: Whether the declared transaction value of imported goods could be rejected and the assessable value enhanced on the basis of a market inquiry without recording reasons under the customs valuation rules.

Analysis: The declared price of imported swimming goggles could not be discarded unless the conditions for rejection of transaction value were satisfied under the valuation rules. No reason was recorded for treating the invoice value as unacceptable. The market inquiry also suffered from infirmities because identical goods were stated to be unavailable, the comparison was made with other Chinese-origin items though the imported goods were of Taiwan origin, and the basis for converting retail prices into CIF value was not explained.

Conclusion: The enhancement of value was unjustified and the declared transaction value was required to be accepted; the issue is decided in favour of the assessee.

Final Conclusion: The appellate order rejecting the challenge to valuation was set aside and the assessee obtained consequential relief in law.

Ratio Decidendi: Declared transaction value under the customs valuation regime cannot be rejected unless legally sustainable reasons are recorded, and enhancement based on an unreliable market inquiry or non-comparable goods is impermissible.

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