Customs valuation cannot rest on an unauthenticated quotation; declared transaction value stands without proof of undervaluation.

Declared transaction value under the Customs Act could not be rejected merely on the basis of an unsigned and unauthenticated supplier quotation, because undervaluation had to be proved by the Revenue with acceptable evidence and the declared price could be discarded only in accordance with the valuation rules. The importer's invoices supported the negotiated price, and a quotation obtained by DRI, without authentication, was insufficient to justify enhancement of assessable value. The rejection of transaction value and the resulting enhancement were therefore unsustainable, in favour of the assessee.

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Issues: Whether the customs authorities were justified in rejecting the transaction value and enhancing the assessable value of the imported goods on the basis of an unauthenticated supplier quotation.

Analysis: The importer had supported the declared value by invoices showing the negotiated price. The burden to prove undervaluation lay on the Revenue, and the declared transaction value could be discarded only in accordance with Section 14 of the Customs Act and the applicable valuation rules. The enhancement made by relying on an unsigned and unauthenticated quotation obtained by DRI was not supported by acceptable evidence. The cited authorities made it clear that such a quotation cannot, by itself, form the basis for rejecting the declared value or for resorting to enhanced valuation.

Conclusion: The rejection of the transaction value was unjustified and the enhancement based on the unauthenticated quotation was unsustainable. The finding is in favour of the assessee.

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