Declared transaction value cannot be rejected without recorded reasons; contemporaneous import data is only an aid in customs valuation.

Declared transaction value under the Customs Valuation Rules could not be rejected merely on the basis of contemporaneous import data. The proper officer had to examine the importer's documents, seek clarification where necessary, and record valid reasons for doubting and discarding the invoices and supporting materials before invoking Rule 12. Because no adequate reasons were recorded for rejecting the declared value, reliance on NIDB or similar data alone was insufficient to substitute an assessable value. The rejection of transaction value was therefore held unsustainable and the assessee's appeals succeeded.

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Issues: Whether the rejection of the declared transaction value under Rule 12 of the Customs Valuation Rules, 2007 was sustainable when no adequate reasons were recorded for discarding the import documents and contemporaneous data was relied upon.

Analysis: Rule 12 permits rejection of the declared value only when the proper officer, after seeking necessary clarification and examining the supporting documents, records valid reasons for doubting the correctness of the value and for discarding the documentary evidence furnished by the importer. Reliance on NIDB or contemporaneous import data is only an indicator and cannot by itself substitute for assessable value. The assessing authority was required to explain why the invoices, packing list, certificate of origin and other materials produced by the importer were not accepted. As no such reasons were available, the procedural requirements for rejection of the transaction value were not satisfied.

Conclusion: The rejection of transaction value was unsustainable and the appeals were allowed in favour of the assessee.

Ratio Decidendi: Declared transaction value under the customs valuation regime cannot be rejected unless the proper officer records valid reasons, based on examination of the importer's documents and material, for doubting and discarding the declared value; contemporaneous import data is only an aid and not a substitute for assessable value.

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