Transaction value for second-hand machinery cannot be rejected for certificate discrepancies without recognised valuation grounds.

In valuation of second-hand imported machinery, the declared transaction value cannot be rejected merely because a Chartered Engineer's certificate shows a discrepancy in the year of manufacture. Under section 14 of the Customs Act and Rules 3 and 4 of the Customs Valuation Rules, transaction value remains the starting point and may be discarded only on recognised grounds such as fraud, abnormal consideration, related-party influence, or reliable contemporaneous higher imports. Where such grounds are not established, valuation cannot be enhanced through an expert appraiser's opinion or a best-judgment approach, and the rule-based valuation sequence must be followed first.

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Issues: Whether the declared transaction value of imported second-hand machinery could be rejected merely because the Chartered Engineer's certificate contained a discrepancy in the year of manufacture, and whether valuation could then be enhanced without following the Customs Valuation Rules.

Analysis: The declared value of second-hand machinery cannot be discarded only because the Chartered Engineer's certificate does not tally with the year of manufacture shown on the equipment. Under section 14 of the Customs Act and Rules 3 and 4 of the Customs Valuation Rules, transaction value remains the starting point and can be rejected only on legally recognised grounds. The record did not show any fraud, abnormal consideration, related-party influence, or contemporaneous imports at higher values sufficient to displace the declared value. Once the transaction value was not validly rejected, enhancement on an expert appraiser's opinion or by a best-judgment approach was not sustainable. Rule-based valuation had to be applied before resorting to any alternate basis.

Conclusion: The declared transaction value was required to be accepted in law, and the enhancement of value was unsustainable.

Ratio Decidendi: In valuation of second-hand imported goods, the transaction value cannot be rejected merely because the Chartered Engineer's certificate contains an incorrect year of manufacture; rejection must rest on grounds recognised by the Customs Valuation Rules, with transaction value remaining the primary rule.

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