Customs valuation cannot be enhanced on vague contemporaneous imports without credible evidence against the declared transaction value.

Declared transaction value under customs valuation law cannot be rejected or enhanced merely by referring to contemporaneous imports unless the department produces credible supporting material and disproves the importer's invoice, contract, banking trail and other documents. On the facts noted, the authorities had not produced the relied-upon contemporaneous bill of entry or any contrary evidence against the payment records, so the enhanced value was unsustainable. The accepted transaction value was therefore maintained and the Revenue's challenge failed.

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Issues: Whether the declared transaction value of imported goods could be rejected and the value enhanced on the basis of contemporaneous imports without furnishing reliable supporting material and without disproving the importer's documents and banking records.

Analysis: The appeal challenged the first appellate authority's finding that the declared invoice value could not be discarded on mere reference to contemporaneous imports. The record showed that the department did not produce the contemporaneous bill of entry relied upon, did not establish any contrary evidence against the importer's banking payment trail, and did not dislodge the genuineness of the contract and related documents. In such circumstances, the declared transaction value could not be rejected in an arbitrary manner, and enhancement could not rest only on unsupported references to higher import prices.

Conclusion: The declared transaction value was correctly accepted and the proposed enhancement of value was not sustainable; the Revenue's appeal failed.

Final Conclusion: The dispute was resolved in favour of the importer, and the order rejecting enhancement of customs value was maintained.

Ratio Decidendi: Transaction value under customs valuation law cannot be rejected or enhanced merely on vague reference to contemporaneous imports unless the department produces credible supporting evidence and disproves the declared value and supporting documents.

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