Customs valuation requires recorded reasons before rejecting declared value; routine enhancement without a speaking order is unsustainable.

Declared transaction value in customs valuation must be accepted unless lawfully rejected under the Customs Valuation Rules on recorded reasons and permissible comparative data. Routine enhancement based on NIDB data or loading, without a speaking order and without proper comparison with contemporaneous imports, is impermissible. The importer's written acceptance of enhancement, given under compulsion to obtain clearance and avoid demurrage, did not bar appellate challenge. The declared value was restored and reassessment at the enhanced value was rejected.

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Issues: Whether the declared transaction value of imported goods could be enhanced without a speaking order and on the basis of routine loading or NIDB data, and whether the importer's written acceptance of enhancement barred challenge in appeal.

Analysis: The assessment of imported goods is to be made on the transaction value unless the case falls within the recognised exceptions under the Customs Valuation Rules. Where the declared value is rejected, the proper officer must record reasons and discharge the burden of showing that the invoice value does not reflect the true transaction value. Routine enhancement, without proper comparison with contemporaneous imports and without a reasoned order, is not sustainable. The importer's acceptance of enhancement was found to have been made under compulsion to secure clearance of the goods and to avoid demurrage, and did not prevent appellate challenge. The prior order in the importer's own case and the Tribunal's earlier view on similar facts also supported acceptance of the declared value.

Conclusion: The enhancement of value was not justified, and the declared value was correctly restored. The Revenue's appeal failed.

Final Conclusion: The common order of the Commissioner (Appeals) was upheld and the Revenue's challenge to reassessment at the enhanced value was rejected.

Ratio Decidendi: In customs valuation, the declared transaction value must be accepted unless it is lawfully rejected on recorded reasons and the proper officer establishes, with reference to permissible valuation criteria, that the declared value is not true; routine enhancement without a speaking order is impermissible.

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