Customs valuation by comparable lot pricing prevails when declared import price lacks reliable trade evidence.

Declared invoice value is not automatically accepted for customs assessment if it is not supported by reliable documentary evidence showing that the price was ordinarily available in international trade. In this note, the valuation issue turned on imported large lots compared with smaller comparable lots, and the claimed bulk-purchase justification was not adequately proved by published price lists, discount schedules, or similar material. The accepted price differential between larger and smaller lots therefore governed valuation, and the assessable value had to be recalculated on that basis, giving the importer corresponding relief.

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Issues: Whether the declared invoice price of the imported goods could be accepted for assessment under Section 14 of the Customs Act, 1962, or whether the assessable value had to be determined with reference to the price of comparable smaller lots.

Analysis: The goods were imported in large lots, while the comparable imports relied upon by the department were in much smaller quantities. The declared price for the appellants was substantially lower than the price charged in earlier and comparable transactions. The explanation for the lower price was that bulk purchase and prior sourcing from another supplier enabled a special price, but no published price list, discount schedule, or other documentary material was produced to show that such price was ordinarily available in the course of international trade to independent buyers. The price pattern over the years also did not support the claimed justification for the very wide differential. The explanation for the higher price of smaller lots was accepted, but the same basis did not adequately explain the much lower price claimed for the larger lots.

Conclusion: The declared invoice price of the appellants was not acceptable for assessment under Section 14 of the Customs Act, 1962. The assessable value was to be worked out by applying the accepted price differential between larger and smaller lots, with consequential relief to the appellants.

Final Conclusion: The appeal succeeded only to the extent that the assessable value was to be recalculated on the indicated basis, and the appellants obtained corresponding relief.

Ratio Decidendi: Where a declared import price is not shown by reliable documentary evidence to be the price ordinarily available in international trade, and comparable evidence supports valuation by reference to like goods and established lot-based differentials, the declared price need not be accepted for customs assessment.

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