Declared transaction value cannot be rejected merely because similar imports were assessed higher; objective proof of inaccuracy is required.

Declared transaction value under customs law remains the basis of assessment where buyer and seller are unrelated and price is the sole consideration. Rule 12 permits rejection only on objective grounds, after inquiry, if the proper officer still has reasonable doubt about the truth or accuracy of the declared value. Contemporaneous imports at higher values, by themselves, do not prove under-valuation or justify enhancement, especially when those higher values are themselves disputed. The declared invoice price must be rejected only on cogent material showing it is not genuine; absent that proof, assessment must proceed on the declared transaction value.

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Issues: Whether the declared transaction value of imported goods could be rejected and enhanced merely because contemporaneous imports of similar goods had been assessed at higher values.

Analysis: Section 14 of the Customs Act, 1962 treats the transaction value as the basis of assessment when the buyer and seller are not related and price is the sole consideration. Rule 12 of the Customs Valuation Rules, 2007 permits rejection of the declared value only where the proper officer has reason to doubt its truth or accuracy and, after inquiry, still has reasonable doubt. The mere existence of contemporaneous imports at higher values does not by itself establish that the declared price is false or that there has been under-valuation. The Department must bring cogent material showing that the invoice price is not genuine; higher values that are themselves the subject of adjudication cannot be used as the sole benchmark to reject the declared value.

Conclusion: The rejection of the declared transaction value and the consequent enhancement of assessable value were not sustainable.

Final Conclusion: The import valuation was required to be assessed on the declared transaction value, and the enhancement was set aside.

Ratio Decidendi: A declared transaction value under customs law cannot be rejected merely because contemporaneous imports reflect higher disputed values; rejection requires objective grounds and proof that the declared price is not genuine.

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