Transaction value cannot be rejected using incomparable origin data where comparable imports support the declared value.

Declared import value may be rejected only on legally sustainable grounds. Valuation data relating to sawn wood of different origins could not be used to displace the declared value of Ghana Sawn Teak, because the comparable goods did not match the imported goods or their country of origin. Contemporaneous material also showed imports of comparable Ghana teak goods at substantially similar values during the relevant period, supporting the transaction value. On that basis, rejection of the declared value was unsustainable, the valuation order was set aside, and the importer's declared value was accepted.

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Issues: Whether the declared value of imported Ghana Sawn Teak could be rejected on the basis of valuation data relating to sawn wood of Cameroon and Malaysian origin, and whether resort to the deductive valuation method was justified.

Analysis: The declared transaction value can be rejected only on legally sustainable grounds. The relied-upon valuation data did not match either the description of the imported goods or their country of origin. The comparison was with sawn wood from different origins, while the imports in question were Ghana Sawn Teak. The available contemporaneous material also indicated imports of comparable Ghana teak goods at substantially similar values during the relevant period. In these circumstances, the basis for rejecting the declared value was not established.

Conclusion: The rejection of the declared value was unsustainable and the appeal succeeded.

Final Conclusion: The impugned valuation order was set aside and the importer's declared value was accepted.

Ratio Decidendi: Declared import value cannot be rejected by relying on incomparable goods or mismatched country-of-origin data when contemporaneous comparable imports support the transaction value.

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