Declared transaction value cannot be rejected without disclosed reasons and supporting material under the customs valuation rules.

Rejection of declared transaction value under the Customs Valuation Rules requires a reasoned speaking order identifying the material that makes the declared value unacceptable; mere doubt is insufficient. The record did not disclose adequate reasons or supporting material to justify rejection, so the valuation could not be sustained. A precedent arising under the earlier Customs Valuation Rules, 1988 regime was also not mechanically applicable to the impugned imports under the later valuation framework. The valuation determination was therefore set aside for fresh consideration, with liberty to the importer to raise all other pleas before the original authority.

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Issues: Whether the rejection of the declared transaction value under Rule 12 of the Customs Valuation Rules, 2007 was justified, and whether reliance on the earlier valuation precedent was appropriate for the impugned imports.

Analysis: The rejection of transaction value must rest on a speaking order setting out why the declared value is not acceptable and identifying the material on which such rejection is based. The reasoning also noted that the precedent relied upon concerned an earlier import under the Customs Valuation Rules, 1988, whereas the mechanism akin to Rule 12 was introduced later by Notification No. 10/98-Cus (NT) dated 19.02.1998. On the record, only doubt had been raised and there was insufficient disclosure of reasons or supporting material to justify rejection of the declared value.

Conclusion: The rejection of transaction value was held to be unsustainable on the existing record and the matter was remanded for fresh decision without being influenced by the earlier precedent.

Final Conclusion: The adjudication on valuation was set aside for reconsideration, with liberty to the importer to raise all other pleas before the original authority.

Ratio Decidendi: Rejection of declared transaction value requires a reasoned speaking order based on disclosed material, and a precedent under a materially different valuation regime cannot be mechanically applied to justify such rejection.

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