Consensual customs valuation enhancement bars later challenge when duty is paid without protest and revision is accepted in writing.

An importer who consented in writing to an enhanced assessable value and paid duty without protest was treated as having accepted the revision, making a later challenge to that valuation untenable. The commentary states that, where a show cause notice was waived at the importer's request, the Revenue was not required to further prove the valuation, and natural justice could not be used to reopen the accepted assessment. It also notes that a re-determination supported by NIDB data was not shown to be arbitrary or unreasonable, and prior precedent was said to favour estoppel against a party that voluntarily accepts the revised value.

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Issues: Whether the importer could later challenge the enhanced assessable value after having consented in writing to the revision and paid duty without protest, and whether the re-determination of value under the customs valuation rules was arbitrary.

Analysis: The lower authorities had recorded that the importer had agreed in writing to the revised value and had paid duty at the enhanced value without protest. On that footing, the importer's later denial of acceptance of the revised transaction value was untenable. Once enhancement was consented to and a show cause notice was foregone at the importer's request, the Revenue was not required to establish the valuation further. In such circumstances, the principles of natural justice could not be invoked to reopen the valuation. The challenge was also unsupported on merits, as the revaluation was based on NIDB data and was not shown to be arbitrary or unreasonable. The earlier precedents relied upon by the Tribunal supported the view that an importer who voluntarily accepts enhanced value and pays duty accordingly is estopped from disputing it later.

Conclusion: The challenge to the enhanced valuation was rejected, and the appeal failed.

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