Declared transaction value cannot be rejected on quotations or dissimilar imports without reliable comparable evidence.

Declared transaction value under Section 14 of the Customs Act, 1962 and the Customs Valuation Rules, 1988 cannot be rejected on quotations alone, because quotations are only indicative and do not prove the relevant import conditions. Comparison with alleged contemporaneous imports must rest on reliable, comparable evidence, including quantity and country of origin, and non-supply of relied-upon material causes prejudice. On the stated facts, the Revenue failed to prove undervaluation with acceptable evidence, so the valuation enhancement, duty demand, confiscation, and penalties could not stand.

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Issues: Whether the declared import value could be rejected and the goods revalued on the basis of quotations and alleged contemporaneous imports, thereby sustaining the finding of undervaluation and the consequential duty and penalties.

Analysis: The assessable value under Section 14 of the Customs Act, 1962 and the Customs Valuation Rules, 1988 could not be determined on the basis of quotations alone, since quotations are only indicative and do not establish the relevant import conditions, including country of origin and quantity. The material relied upon for comparison was found wanting because, in some instances, the contemporaneous import data did not reflect the quantity, the country of origin was different, and one relied-upon Bill of Entry had not been supplied, causing prejudice. On the facts, the Revenue failed to discharge the burden of proving undervaluation by acceptable evidence.

Conclusion: The rejection of the declared value was unsustainable and the assessee succeeded; the valuation enhancement, duty demand, confiscation, and penalties could not stand.

Ratio Decidendi: Declared transaction value cannot be rejected on quotations or dissimilar import instances unless the Revenue proves undervaluation with reliable comparable evidence satisfying the statutory valuation framework.

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