Transaction value in customs valuation cannot be rejected without cogent evidence of undervaluation or extra consideration.

Declared transaction value of imported PU belts with buckles could not be rejected where the invoice value matched the purchase price from the foreign manufacturer and Revenue produced no evidence of undervaluation or extra consideration. Transaction value remains the starting point under the Customs Valuation Rules, 2007, and can be discarded only on cogent grounds. Website prices, NIDB data and market enquiries were unreliable because the goods were not shown to be identical or comparable, and leather belts could not be equated with PU belts. Earlier imports of identical goods from the same supplier at the same price also supported acceptance of the declared value, so enhancement was unsustainable.

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Issues: Whether the declared transaction value of imported PU belts with buckles could be rejected and enhanced in the absence of evidence showing undervaluation or additional consideration.

Analysis: The declared invoice value matched the purchase price from the foreign manufacturer, and the Revenue did not produce evidence that the stated value was incorrect or that any extra consideration flowed back to the supplier. Under the Customs Valuation Rules, 2007, transaction value is the starting point for valuation and can be discarded only on cogent grounds. The alleged comparison with website prices, NIDB data, and market enquiries was not reliable because the cited goods were not shown to be identical or comparable, and leather belts could not be equated with PU belts. The earlier import of identical goods from the same supplier at the same declared price was also relevant contemporaneous evidence supporting acceptance of the declared value.

Conclusion: The declared transaction value could not be rejected, and the enhancement of value was unsustainable.

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