Customs valuation: declared transaction value stands unless a recognised exception applies; comparison with non-identical imports is insufficient.

Declared import value must be accepted under the Customs Valuation Rules unless the department establishes a recognised exception justifying rejection of transaction value. In this case, enhancement based on comparison with other imports failed because the relied-upon goods came from different countries and were not shown to be identical or similar for valuation purposes. The later Rule 10A could not be invoked for imports made before its introduction, and the declared price was not shown to be unrealistically low merely because other consignments of different quantity or origin fetched different prices. The declared value was therefore upheld and no substitution of a higher value was warranted on the facts.

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Issues: Whether the declared import value could be rejected and enhanced on the basis of other imports, and whether the comparison made with different goods from different countries justified valuation under the Customs Valuation Rules.

Analysis: The declared transaction value is to be accepted unless a recognised exception under the valuation rules applies. The imports in question were made in 1997, before the introduction of Rule 10A, so reliance on later valuation principles was not available. The goods compared by the department were imported from different countries and were not shown to be identical or similar goods for the purposes of Rules 5 and 6. The Court also found no basis to treat the declared price as absurdly unrealistic merely because other consignments of different quantities or origins fetched different prices.

Conclusion: The enhancement of value was not justified and the declared value was upheld in favour of the assessee.

Final Conclusion: The department failed to establish any ground for rejecting the transaction value or for substituting a higher value on the facts of the case.

Ratio Decidendi: In the absence of a recognised exception under the valuation rules, the declared transaction value must be accepted, and enhancement cannot rest on comparison with non-identical or non-similar imports.

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