Customs valuation must follow declared transaction value unless reliable evidence justifies rejection; unsupported age findings on second-hand machinery fail.

Imported second-hand printing machinery could not be treated as over 10 years old on the basis of accessory markings or an unsupported assumption about manufacture year, so the clearance objection on age failed. The declared transaction value also could not be rejected because Section 14 of the Customs Act and Rule 4 of the Customs Valuation Rules make transaction value the primary basis unless lawfully displaced by reliable evidence; depreciation-based revaluation and unverified comparative import data were insufficient. Confiscation, enhancement of value, penalty, and related directions were therefore unsustainable, and relief was granted.

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Issues: (i) Whether the finding that the imported second-hand printing machine was more than 10 years old and therefore liable to be denied clearance could be sustained; (ii) Whether the declared transaction value could be rejected and the goods revalued by applying depreciation or purported contemporaneous import data.

Issue (i): Whether the finding that the imported second-hand printing machine was more than 10 years old and therefore liable to be denied clearance could be sustained.

Analysis: The age finding rested only on markings on accessories such as the control panel and on an incorrect assumption regarding the breakup of Czechoslovakia. The markings on accessories could not safely determine the manufacture year of the machine itself, especially when other accessories showed different years. The material relied upon was insufficient to support the conclusion that the machine was of 1991 manufacture.

Conclusion: The finding that the machine was more than 10 years old was unsustainable and the clearance objection on that basis failed.

Issue (ii): Whether the declared transaction value could be rejected and the goods revalued by applying depreciation or purported contemporaneous import data.

Analysis: Under Section 14 of the Customs Act and Rule 4 of the Customs Valuation Rules, transaction value is the primary basis of assessable value unless there is legal ground to reject it. There was no material showing any consideration other than the invoice price. A depreciation-based estimate could not displace the actual transaction value merely because it was lower. The cited comparative price was not taken from a proper contemporaneous import record and did not provide a valid basis for enhancement.

Conclusion: Rejection of the declared value and enhancement of assessable value were unjustified.

Final Conclusion: The confiscation, enhancement of value, penalty, and related directions could not be sustained, and the appellant was entitled to relief.

Ratio Decidendi: In customs valuation, the declared transaction value of imported goods must prevail unless lawfully dislodged by reliable evidence, and the age of second-hand machinery cannot be determined from accessory markings or conjecture unsupported by evidence.

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