Customs valuation requires recorded reasons and valid comparable imports before rejecting declared transaction value.

Declared transaction value of imported goods may be rejected only where the conditions in the proviso to Rule 3(2) of the Customs Valuation Rules, 2007 are not met or, after following Rule 12, the proper officer records reasons to doubt the correctness of the declared value. Here, the assessing authority enhanced the unit price of imported motherboards without giving reasons, and the relied-upon contemporaneous import was not a valid comparator because it covered goods classifiable under a different tariff heading. On that material, rejection of the declared value was unsustainable and the enhancement could not be upheld.

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Issues: Whether the declared transaction value of imported goods could be rejected and enhanced on the basis of contemporaneous imports without recording reasons and without showing that the relied-upon import related to identical or similar goods.

Analysis: The declared unit price of the motherboards was enhanced by the assessing authority without assigning reasons. Rejection of the declared transaction value is permissible only when the conditions in the proviso to Rule 3(2) of the Customs Valuation Rules, 2007 are not satisfied or when, after following Rule 12 of the Customs Valuation Rules, 2007, the proper officer records reasons to doubt the correctness of the declared value. The relied-upon bill of entry also pertained to goods classifiable under a different tariff heading, while the imported goods in the present case were plain motherboards under another heading, so the comparison was not valid.

Conclusion: The enhancement of value was unsustainable and the assessee's declared value could not be rejected on the material relied upon by the Revenue.

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