Export valuation requires recorded reasons before rejecting declared FOB value; market enquiry alone is insufficient.

Declared FOB value of export goods cannot be rejected on market enquiry alone unless the proper officer first records cogent reasons for doubting its correctness and then redetermines value in the prescribed manner. The required sequence under the export valuation regime is to examine the declared value first, identify independent material justifying doubt, and only then proceed to valuation reassessment. A mere discrepancy between the declared value and market enquiry result is not enough by itself to sustain rejection where no separate basis for doubt is shown. On that footing, the rejection and redetermination were held unsustainable.

---

---

Issues: Whether the declared FOB value of the export goods could be rejected and redetermined solely on the basis of market enquiry without first recording cogent reasons.

Analysis: The adjudicating authority was required to first examine the correctness of the declared export value and record cogent reasons for doubting it before proceeding to redetermine value under the export valuation rules. The record showed that the value was first redetermined on the basis of market enquiry and only thereafter rejected, which reversed the mandatory sequence. The discrepancy between the declared value and the market enquiry value was not by itself treated as sufficient to establish a legally sustainable basis for rejection, and no independent material was shown to justify rejection of the declared value in the manner required by law.

Conclusion: The rejection and redetermination of the declared export value were not sustainable, and the departmental appeal failed.

Ratio Decidendi: Under the export valuation regime, declared value cannot be rejected on market enquiry alone unless the proper officer first records cogent reasons for doubting its correctness and then proceeds to redetermine value in the prescribed manner.

---