Customs value cannot be revised using post-clearance documents; later invoices are not clerical errors under the Act.

Post-clearance amendment of a Bill of Entry and imported value under section 149 of the Customs Act is permissible only on the basis of documentary evidence already in existence at the time of import, and not on revised purchase orders or invoices created later. Since the revised documents were post-clearance instruments and the original transaction could not be verified through contemporaneous evidence, the requested value alteration was rejected. Section 154 was also inapplicable because it covers only clerical, arithmetical, or accidental mistakes, and the dispute concerned a substantive reassessment of declared value rather than a correction slip. The declared customs value therefore remained unchanged.

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Issues: (i) Whether the Bill of Entry and imported value could be amended under section 149 of the Customs Act, 1962 on the basis of revised purchase order and revised invoice generated after clearance of the goods. (ii) Whether the alleged excess duty payment could be reopened and rectified under section 154 of the Customs Act, 1962 as a clerical error.

Issue (i): Whether the Bill of Entry and imported value could be amended under section 149 of the Customs Act, 1962 on the basis of revised purchase order and revised invoice generated after clearance of the goods.

Analysis: Section 149 permits amendment of a document only in the discretion of the proper officer and, after clearance of imported goods, such amendment can be authorised only on the basis of documentary evidence that was already in existence when the goods were cleared. The revised purchase order and revised invoice were created later and were not shown to be part of the original transaction at the time of import. The goods were not examined at the time of import and could not be verified later for the purpose of testing the genuineness of the revised documents. A quotation, by itself, was not treated as the agreed contract price, while the purchase order and commercial invoice were treated as the governing commercial documents. On these facts, the request was held to be one for alteration of value based on post-import documents and not a permissible amendment supported by contemporaneous evidence.

Conclusion: The amendment claim under section 149 was not maintainable and was rejected.

Issue (ii): Whether the alleged excess duty payment could be reopened and rectified under section 154 of the Customs Act, 1962 as a clerical error.

Analysis: Section 154 applies only to clerical or arithmetical mistakes or accidental slips or omissions in a decision or order. The dispute did not arise from any clerical mistake in the bill of entry, invoice, or assessment order, but from a later attempt to substitute the declared value with a revised value derived from subsequent documents. The assessment had been completed on the declared transaction value, and the case did not disclose an accidental slip capable of correction under section 154. The later reassessment request was therefore outside the scope of section 154.

Conclusion: Relief under section 154 was not available and was rejected.

Final Conclusion: The assessment could not be reopened on the basis of post-clearance documents, and the declared customs value remained undisturbed.

Ratio Decidendi: Post-clearance amendment of customs documents affecting value is permissible only when supported by contemporaneous documentary evidence existing at the time of import, and a later revision of commercial documents cannot be treated as a clerical error or as a basis for reassessment.

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