Customs valuation turns on real transaction price and comparable imports; unsupported undervaluation cannot displace the invoice price.

Under Section 14 of the Customs Act, assessable value is the ordinary sale price at the time and place of importation where buyer and seller are independent and price is the sole consideration. The burden to prove undervaluation lies on the revenue, and an invoice price cannot be rejected without reliable evidence that it is not the real transaction price. Here, the old price list was insufficient, while revised pricing, negotiated commercial discounts, and comparable imports supported the declared value. The invoice prices therefore had to be accepted as the assessable value for customs duty purposes.

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Issues: Whether the invoice prices of the imported ball bearings could be rejected as undervalued for assessment of customs duty, and whether the goods were liable to be assessed on the basis of the supplier's earlier price list with a limited discount.

Analysis: Under Section 14 of the Customs Act, 1962, assessable value is the price at which such or like goods are ordinarily sold or offered for sale at the time and place of importation in the course of international trade, where the seller and buyer have no interest in each other's business and the price is the sole consideration. The burden to prove undervaluation lies on the revenue. In the present case, the only primary reliance placed by the revenue was an old price list, while the record also contained material showing a revised pricing policy, negotiated discounts linked to quantity and category of buyer, and comparable imports by several other importers at similar or even lower prices. There was no material to show that the invoice price was not the real price, or that any extra consideration passed between the parties.

Conclusion: The invoice prices could not be rejected, and they had to be accepted as the assessable value for customs duty purposes.

Ratio Decidendi: In the absence of reliable evidence proving that the apparent invoice price is not the real price, and where comparable imports and commercial discounting support the transaction price, undervaluation under Section 14 of the Customs Act, 1962 is not established.

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