Transaction value under Customs valuation law cannot be enhanced without reasoned rejection and supporting evidence.

Declared transaction value under Section 14 of the Customs Act must ordinarily be accepted as the price actually paid or payable, and the Department can depart from it only on cogent reasons and supporting evidence showing that the declared price is not the sole consideration or that comparable imports justify rejection. Mere suspicion, market trends, or unsupported enhancement is insufficient. The valuation enhancement was therefore unsustainable, and the assessment orders were liable to be set aside.

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Issues: Whether the Revenue could enhance the declared value of imported goods without first rejecting the transaction value under Section 14 of the Customs Act.

Analysis: The normal rule under Section 14 of the Customs Act is acceptance of the price actually paid or payable as the transaction value. Departure from that rule is permissible only on the basis of cogent reasons and supporting material showing that the declared price is not the sole consideration or that comparable imports of identical or similar goods at a higher price justify rejection of the declared value. Mere suspicion, comparison with general market trends, or enhancement without recording reasons is insufficient.

Conclusion: The declared transaction value could not be enhanced without a reasoned rejection of that value, and the Revenue's action was unsustainable.

Final Conclusion: The assessment orders enhancing value were liable to be set aside and the importer was entitled to relief in accordance with law.

Ratio Decidendi: Declared transaction value must be accepted unless the Department proves, with cogent reasons and evidence, that it is not the sole consideration or is otherwise unacceptable under the valuation rules.

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