Customs valuation requires genuine comparable imports before rejecting declared transaction value for imported furniture.

Declared transaction value in customs valuation cannot be rejected unless the department proves genuine comparable or similar goods capable of supporting re-determination. Furniture cannot be treated as comparable merely because it falls within the broad category of furniture, since design, size, materials, filling, upholstery, brand and model can materially affect value. Where the record does not establish commercially interchangeable imports and there is no basis to doubt the genuineness of the declared value, rejection of the transaction value is not justified and the declared value must be accepted.

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Issues: Whether the declared transaction value of imported furniture could be rejected and re-determined on the basis of allegedly comparable imports and weight-based loading.

Analysis: The valuation dispute turned on whether the goods relied upon by the department were truly similar or commercially interchangeable with the imported furniture. The relevant valuation framework required assessment of contemporaneous imports of comparable goods, and the declaration furnished by the importer under the public notice covered the material particulars needed for valuation. Furniture of the kind imported could not be treated as comparable merely because it fell within the broad category of furniture, since design, size, materials, filling, upholstery, brand and model materially affect value. In the absence of established comparable or similar goods, and with no showing that the declared transaction value was not genuine, rejection of the declared value was not justified.

Conclusion: The rejection of the transaction value was unsustainable and the declared transaction value was accepted.

Ratio Decidendi: Declared transaction value under customs valuation cannot be rejected unless the department establishes genuine comparable or similar goods capable of supporting re-determination under the valuation rules.

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