Export assessable value may be based on final invoice and Bank Realization Certificate when actual realisation is uncontroverted.

The final invoice and Bank Realization Certificate were accepted as reliable evidence of the amount actually realised on export, because no contrary material showed receipt of any sum beyond the invoice amount. On that basis, the assessable value was correctly finalised using those documents. The Commissioner (Appeals) had already addressed the department's objections in a reasoned order, and no infirmity was found in that appellate decision. The departmental challenge therefore failed, and the appellate order was sustained with the appeal rejected.

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Issues: Whether the Bank Realization Certificate and final invoice were to be accepted for finalising the assessable value of the exported goods, and whether the department's appeal against the Commissioner (Appeals)'s order deserved interference.

Analysis: The final invoice and Bank Realization Certificate showed the amount actually realised by the exporter, and there was no material showing receipt of any amount beyond what was reflected in the final invoice. The Commissioner (Appeals) had considered the department's objections and had passed a reasoned order. In these circumstances, the Bank Realization Certificate was entitled to credibility and reliance for determining the assessable value, and no infirmity was found in the appellate order.

Conclusion: The assessable value was rightly finalised on the basis of the final invoice and Bank Realization Certificate. The department's challenge failed and the appeal was liable to be dismissed.

Final Conclusion: The appellate order was sustained and the departmental appeal stood rejected.

Ratio Decidendi: Where the final invoice and Bank Realization Certificate establish the actual realisation and there is no contrary evidence, those documents may be relied upon for finalising export assessable value.

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