Customs valuation requires reasoned rejection of transaction value; enhancement fails without evidence of comparable imports or a speaking order.

Declared transaction value for imported goods cannot be rejected unless customs authorities first record legally sustainable reasons and support them with clear, cogent evidence. Where the bill of entry contains no reasons for rejection, no speaking order is passed, and no evidence of contemporaneous imports or comparable quantities is produced, enhancement of value is not justified. Mere upward revision of the invoice value, without demonstrating that the declared value is unacceptable under customs valuation principles, is insufficient. The enhancement was set aside.

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Issues: Whether the enhancement of the declared value of imported goods was sustainable in the absence of reasons, evidence of contemporaneous imports, or a speaking order rejecting the transaction value.

Analysis: The declared transaction value cannot be discarded unless the Department first records legally sustainable grounds and supports the rejection with clear and cogent evidence. Where no reason is stated on the bill of entry, no speaking order is passed, and no evidence of comparable contemporaneous imports or similar quantities is produced, enhancement of value is not justified. Mere enhancement without demonstrating that the invoice value is unacceptable does not satisfy the requirements governing customs valuation.

Conclusion: The enhancement of value was rightly set aside and the appeal failed.

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