Customs transaction value must stand unless undervaluation is proved with reliable contemporaneous imports and cogent evidence.

Under the Customs valuation framework, declared transaction value of imported goods must be accepted unless the department produces reliable, comparable contemporaneous import evidence and cogent reasons to reject it. Mere NIDB data, alleged prices of other importers, or third-party parallel invoices are insufficient to establish undervaluation, wilful misstatement, or suppression, especially when relied-upon documents are not fully furnished for rebuttal. Where the statutory basis for extended limitation is not properly established and the valuation exercise does not follow the required sequential method, re-determination of value, demand, and penalty cannot be sustained.

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Issues: Whether the declared transaction value of imported glass sheets could be rejected and re-determined on the basis of contemporaneous import data and alleged parallel invoices, and whether the demand and penalties were sustainable in view of limitation and denial of relied upon documents.

Analysis: Rejection of transaction value under the Customs valuation framework requires cogent material showing that the declared price is unacceptable, supported by comparable contemporaneous imports of like goods. Mere reliance on NIDB data, alleged higher or lower prices of other importers, or recovery of parallel invoices from third parties does not by itself establish wilful misstatement, suppression, or undervaluation, particularly when the records relied upon are not furnished in full for rebuttal. The record also showed that the department did not satisfactorily establish the statutory grounds for invoking the extended period or for discarding the declared value, and the valuation exercise did not follow the required legal principles governing acceptance of transaction value and sequential re-determination.

Conclusion: The rejection of declared value and the re-determined value were not justified; the demand failed on limitation as well as on merits, and the penalty could not survive.

Final Conclusion: The appeals succeeded, the impugned order was set aside, and the consequential relief followed in law.

Ratio Decidendi: Under the Customs valuation regime, the declared invoice price must be accepted unless the department discharges the burden of proving undervaluation with reliable evidence of comparable contemporaneous imports and cogent reasons for rejection; suspicion, incomplete disclosure of relied upon materials, or third-party parallel invoices are insufficient to sustain re-determination or extended limitation.

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