Declared transaction value cannot be rejected on non-comparable imports or unreliable market enquiry under customs valuation rules.

Declared transaction value under the Customs Valuation Rules, 1988 cannot be rejected unless the conditions for acceptance of transaction value are not satisfied. Comparable imports must be truly similar in nature, source and quantity; imports from a different supplier in substantially smaller quantity were not suitable benchmarks. In the absence of reliable contemporaneous imports of identical or similar goods, a market enquiry conducted beyond the stipulated period and showing only a marginal difference from the declared value did not justify loading. The rejection of value and proposed enhancement were therefore not sustainable, and acceptance of the transaction value was upheld.

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Issues: Whether the declared value of the imported goods could be rejected and the assessable value enhanced on the basis of contemporaneous imports, market enquiry and alleged misdeclaration under the Customs Valuation Rules, 1988.

Analysis: The declared value may be rejected only when the conditions for acceptance of transaction value are not satisfied under Rule 4(2) of the Customs Valuation Rules, 1988. For adopting comparable imports, the goods relied upon must be truly comparable in nature, source and quantity. The imports cited by the department were from a different supplier and in substantially smaller quantity, making them unsuitable for comparison. In the absence of reliable contemporaneous imports of identical or similar goods, the market enquiry also did not justify loading, particularly when it was conducted beyond the stipulated period and the difference between the declared and proposed values was marginal.

Conclusion: The rejection of the declared value and the proposed enhancement were not sustainable, and the transaction value was rightly accepted.

Final Conclusion: The appeal failed, and the order dropping the proceedings was upheld.

Ratio Decidendi: Declared transaction value under the Customs Valuation Rules, 1988 cannot be discarded or enhanced on the basis of non-comparable imports or an unreliable market enquiry; valuation must rest on legally comparable evidence and substantial, not marginal, variation.

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