Statutory export valuation governs exemption claims; contract price and administrative practice cannot override Customs valuation rules.

Export-duty exemption for jute specialities turned on whether f.a.s. value had crossed the statutory threshold. The Court applied section 14 read with section 2(41) of the Customs Act and held that valuation had to follow the ordinary international trade price at the time and place of export, not the exporter's contract price. Registration certificates, the export-contract registration scheme and administrative letters could not displace the statute or create estoppel against Revenue. It also held that section 28 did not require short-levy notices to state detailed reasons where the assessee knew the basis of the demand. The statutory valuation, valuation re-examination, and notices were therefore upheld.

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Issues: (i) Whether the f.a.s. value of the jute specialities for claiming exemption from export duty under the exemption notification had to be determined under the statutory valuation rule in section 14 read with section 2(41) of the Customs Act, 1962, or according to the contract price and the valuation practice reflected in the registration scheme and administrative letters; (ii) whether the Customs authorities were estopped from re-examining the declared value by reason of the registration certificate, the notification governing registration of export contracts, and the administrative letter said to recognise the trade method of valuation; and (iii) whether the notices and demand under section 28 of the Customs Act, 1962 were bad for want of reasons or grounds.

Issue (i): Whether the f.a.s. value of the jute specialities for claiming exemption from export duty under the exemption notification had to be determined under the statutory valuation rule in section 14 read with section 2(41) of the Customs Act, 1962, or according to the contract price and the valuation practice reflected in the registration scheme and administrative letters.

Analysis: The exemption depended on whether the goods crossed the prescribed f.a.s. value threshold. The Court held that the statutory definition of value in section 2(41) and the valuation principle in section 14 controlled the inquiry. The relevant basis was the ordinary price of such or like goods at the time and place of exportation in the course of international trade, not the particular contract price between the exporter and a buyer. In the absence of evidence showing that the Customs valuation was contrary to that statutory standard, the valuation adopted by the authorities could not be rejected.

Conclusion: The statutory valuation method applied, and the assessee failed to show entitlement to exemption on the basis of the declared contract price.

Issue (ii): Whether the Customs authorities were estopped from re-examining the declared value by reason of the registration certificate, the notification governing registration of export contracts, and the administrative letter said to recognise the trade method of valuation.

Analysis: The notification for voluntary registration did not state that the registration certificate would be conclusive proof of f.a.s. value. It only indicated that the certificate would ordinarily be accepted as sufficient proof of the scope of contract price and related financial items. That administrative arrangement could not override the statutory mandate governing valuation. Any alleged practice or assurance inconsistent with the statute could not create an estoppel against the statute.

Conclusion: No estoppel arose against the Revenue, and the Customs authorities were entitled to re-examine valuation.

Issue (iii): Whether the notices and demand under section 28 of the Customs Act, 1962 were bad for want of reasons or grounds.

Analysis: Section 28 did not expressly require the notice to set out the grounds on which short levy was alleged. The record showed that the petitioners understood the basis of the demand from the show-cause proceedings. The challenge to the notices on this ground therefore could not succeed.

Conclusion: The notices under section 28 were not invalid for absence of reasons or disclosure of grounds.

Final Conclusion: The statutory valuation adopted by the Customs authorities was upheld, the plea of estoppel failed, and the challenge to the short-levy notices was rejected, leaving the Revenue's demand undisturbed.

Ratio Decidendi: Where duty exemption depends on value, the value must be determined strictly according to the governing statute, and administrative practice or representations inconsistent with that statute cannot bind the Revenue or create an estoppel against the law.

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