Declared transaction value cannot be rejected without comparable import evidence and proof supporting enhanced valuation.

Declared transaction value of imported goods may be rejected only on clear and cogent evidence that it is unacceptable under the valuation rules; higher values from an earlier period are insufficient without proof that the goods are comparable in quantity, quality and other material particulars. In the absence of evidence of contemporaneous imports of like goods and no material justifying rejection of the invoice value, enhancement of assessable value cannot be sustained. The declared value was therefore not liable to rejection on the record and the enhanced valuation was not justified.

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Issues: Whether the declared transaction value of imported goods could be rejected and the enhanced value sustained on the basis of higher-value imports from an earlier period without evidence showing sameness of quantity, quality and other relevant comparables.

Analysis: The declared value can be rejected only when the department establishes, by clear and cogent evidence, that the transaction value is not acceptable under the valuation rules. Reliance on higher import values from another period is insufficient unless the goods are shown to be comparable in quantity, quality and other material particulars. In the absence of evidence of contemporaneous import of like goods and in the absence of any material justifying rejection of the invoice value, the enhanced valuation cannot be sustained.

Conclusion: The declared transaction value was not liable to be rejected on the material placed on record, and the enhancement of value was not justified.

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