Customs valuation requires contemporaneous evidence of undervaluation; bare statements cannot displace declared transaction value.

Declared transaction value under customs valuation law cannot be rejected unless the Revenue produces cogent, contemporaneous evidence of undervaluation, such as comparable imports or other reliable material. Valuation ordinarily follows transaction value under Section 14(1) of the Customs Act, 1962 read with Rules 3 and 4 of the Customs Valuation Rules, 2007, and the burden to displace the invoice value rests on the Revenue. A bare importer's statement or voluntary deposit, especially if alleged to have been made under coercion, is insufficient without corroboration. In the absence of proof that the apparent price was not the real price, rejection of value, differential duty, confiscation and penalties were unsustainable.

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Issues: Whether the declared assessable value of the imported goods could be rejected and the differential duty, confiscation and penalties sustained in the absence of comparable import evidence and where the only basis was the importer's statement and voluntary deposits.

Analysis: Valuation of imported goods must ordinarily proceed on the transaction value under Section 14(1) of the Customs Act, 1962 read with Rules 3 and 4 of the Customs Valuation Rules, 2007, and rejection of the declared value requires cogent material showing that the invoice value does not reflect the true value in the ordinary course of international trade. The record contained no contemporaneous comparable imports or other reliable data to justify re-determination of value. The demand was sustained primarily on the importer's statement and deposits, but the burden to prove undervaluation lies on the Revenue, and a statement alleged to have been made under coercion cannot by itself displace the declared value without supporting evidence. In the absence of proof that the apparent price was not the real price, the declared value could not be rejected.

Conclusion: The rejection of the declared assessable value was unsustainable, and the demand for differential duty, confiscation and penalties could not be maintained. The appeal succeeded.

Ratio Decidendi: Declared transaction value under customs valuation law cannot be discarded unless the Revenue produces cogent, contemporaneous evidence of undervaluation, including comparable imports or other reliable material; a bare statement or uncorroborated admission is insufficient.

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