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Issues: Whether the declared transaction value could be discarded and substituted in valuation when the first appellate authority had examined the matter under the Customs Valuation (Determination of Price of Imported Goods) Rules, 2007.
Analysis: The first appellate authority had considered the legal position and recorded reasons for its conclusion. The order reflected application of mind to the valuation issue under the Customs Valuation (Determination of Price of Imported Goods) Rules, 2007. In the absence of documentary support for disturbing the declared transaction value, the proposed mechanical substitution of value was not justified.
Conclusion: The declared transaction value was not liable to be disturbed, and the Revenue's appeal was rejected.
Ratio Decidendi: Declared transaction value cannot be displaced unless valuation is examined on legally sustainable grounds and supported by cogent material.