Valuation of old imported machinery requires adjusted comparison, not mechanical reliance on contemporaneous imports or declared value.

Declared transaction value for old and used imported machinery may be rejected where it is found unreliable, but enhancement to a contemporaneous import value cannot be applied mechanically. A comparison with allegedly identical goods must account for differences in year of manufacture, age, usage and technological features, and the valuation must be supported by reasoned evidence. The chartered engineer's certificate and depreciation guidance for old machinery were accepted as relevant, leading to a depreciated assessable value above the declared value but below the enhanced figure adopted below. Differential duty remained recoverable on the reassessed value.

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Issues: Valuation of old and used imported machinery, rejection of the declared transaction value, reliance on contemporaneous import of allegedly identical goods, and application of depreciation to determine assessable value.

Analysis: The declared value of the imported machines was not accepted because the lower authorities found the transaction value to be unreliable and relied on a contemporaneous import of machinery of the same model. However, the reasoning sustaining enhancement to the higher contemporaneous value was found inadequate because the machinery compared was of a different year of manufacture and no sufficient analysis was given on technological differences or on the impact of age and usage. The certificate of the chartered engineer, which fixed the then value of the machine and showed that the goods were old and used, was not discarded. The depreciation guidance in the circular governing old machinery was also applied to the assessed original value to arrive at a more realistic depreciated value.

Conclusion: The declared value was correctly rejected, but the enhancement to the contemporaneous import value was not sustainable. The assessable value was reduced and fixed at a depreciated figure above the declared value but below the enhancement made by the lower authorities.

Final Conclusion: The appeal succeeded only to the extent of reducing the enhanced assessable value, leaving the declaration rejected and differential duty recoverable on the reassessed value.

Ratio Decidendi: In valuing old and used imported machinery, contemporaneous import data cannot be applied mechanically without accounting for differences in age, usage, and depreciation; the assessable value must reflect a reasoned and adjusted comparison supported by evidence.

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