Import licence and valuation limits for used digital printers: no licence was needed before 28.02.2013, and value could not be enhanced on a certificate alone.

For imports made before 28.02.2013, old and used digital multifunction printers were not subject to a licence requirement, as earlier Tribunal and High Court rulings had already settled the absence of a valid import restriction for the relevant period. The declared import value also could not be enhanced merely on the basis of a Chartered Engineer's certificate; without independent corroborative evidence, such a certificate was insufficient to displace the declared value. The impugned order was sustained and the Revenue's challenge failed on both the licensing and valuation issues.

---

---

Issues: (i) Whether old and used digital multifunction printers could be imported without a licence before 28.02.2013. (ii) Whether the value of the imported goods could be enhanced solely on the basis of a Chartered Engineer's certificate without corroborative evidence.

Issue (i): Whether old and used digital multifunction printers could be imported without a licence before 28.02.2013.

Analysis: The import restriction issue had already been settled in earlier Tribunal and High Court decisions holding that, for the relevant period, there was no restriction on import of the subject goods. The absence of a valid licensing requirement was therefore treated as settled law for imports made before 28.02.2013.

Conclusion: No licence was required for import of the impugned goods before 28.02.2013.

Issue (ii): Whether the value of the imported goods could be enhanced solely on the basis of a Chartered Engineer's certificate without corroborative evidence.

Analysis: Enhancement of value based only on a Chartered Engineer's certificate was held insufficient in the absence of independent corroborative material. The conclusion rested on the principle that a declared value cannot be rejected as misdeclared merely because an enhanced valuation has been suggested by a valuation certificate, unless supported by other evidence.

Conclusion: The value could not be enhanced solely on the basis of the Chartered Engineer's certificate without corroborative evidence.

Final Conclusion: The impugned order was sustained and the Revenue's challenge failed on both the licensing and valuation issues.

Ratio Decidendi: In the absence of a binding import restriction for the relevant period and absent corroborative evidence, neither licence denial nor rejection of declared value can be sustained merely on the strength of a Chartered Engineer's certificate.

---