Declared transaction value cannot be prorata enhanced for higher physical weight where imported goods are assessed by unit.

Imported furniture assessed on a unit basis could not have its declared transaction value enhanced merely because the physical weight found on examination exceeded the weight stated in the invoices and packing lists. The revenue did not dispute the transaction price itself, and the valuation basis was not weight-dependent, so prorata loading of the invoice price had no legal foundation. The valuation enhancement was therefore unsustainable, the impugned order was set aside, and the appeals were allowed with consequential relief.

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Issues: Whether the declared transaction value of imported furniture could be enhanced on a prorata basis merely because the physical weight found on examination was higher than the weight declared in the invoices and packing lists, when the goods were assessed by unit and not by weight.

Analysis: The imported furniture was classified under tariff headings assessed on a piece or unit basis. The declared assessable value was supported by the proforma invoices and the revenue did not dispute the transaction price itself. Since the valuation basis was not weight-dependent, the excess physical weight noticed at examination did not provide a legal basis to alter the transaction value or to load the invoice price proportionately. The attempt to enhance value solely on account of weight variation was therefore unsustainable.

Conclusion: The prorata enhancement of the invoice price was not justified, and the appellants succeeded on the valuation issue.

Final Conclusion: The impugned order was set aside and the appeals were allowed with consequential relief according to law.

Ratio Decidendi: Where imported goods are assessable on a unit basis and the declared transaction value is not disputed, excess physical weight by itself cannot justify prorata loading of value.

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