Transaction value for imported goods cannot be rejected without cogent grounds; valuation enhancement was set aside.

Declared transaction value of imported goods cannot be rejected under the Customs Valuation Rules, 2007 merely because different prices appear against goods under the same description. Where the importer explains that the items are different grades of the same chemical, supports that explanation with technical material and analysis reports, and the department has accepted similar values in later imports, the transaction value remains unimpeached. In the absence of cogent grounds to disbelieve the declared value, enhancement of assessable value is unsustainable. The valuation order was set aside with consequential relief.

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Issues: Whether the declared transaction value of the imported goods could be rejected and the assessable value enhanced under the Customs Valuation Rules, 2007.

Analysis: The declared value had been rejected only because different prices were shown for goods under the same description. The appellant explained that the goods were different grades of the same chemical, used for different purposes, supported by technical write-up, analysis report, and subsequent imports where the department accepted the declared values. No cogent ground was shown for disbelieving the transaction value or for sustaining the enhancement.

Conclusion: The rejection of transaction value and the enhancement of value were unjustified and could not be sustained.

Final Conclusion: The appeal succeeded and the impugned valuation order was set aside with consequential relief.

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