Declared export value and Wet Metric Ton basis govern iron ore assessment where no evidence justifies rejection of transaction value.

Declared export transaction value for iron ore fines cannot be rejected unless substantive evidence shows extra consideration or another valid ground for rejection under section 14(1) of the Customs Act, 1962. The final invoice, sale terms and Bank Realisation Certificate supported the declared value, and there was no material indicating payment beyond invoice price. The chemical report relied on by revenue was defective because it did not state moisture content or whether Fe content was tested on wet or dry basis, while the authorised inspection report recorded moisture content and aligned with the legally prescribed method. Fe content for export duty assessment of iron ore must be determined on Wet Metric Ton basis where required by law.

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Issues: Whether the declared transaction value of exported iron ore fines could be rejected and the export value re-determined on the basis of the Customs House chemical report, and whether assessment of iron ore fines had to be made on Wet Metric Ton basis.

Analysis: The declared export value was supported by the final invoice, the sale terms and the Bank Realisation Certificate, and there was no material showing receipt of any consideration beyond the invoice price. Section 14(1) of the Customs Act, 1962 requires acceptance of the transaction value unless the conditions for rejection are established. The chemical report relied upon by the revenue did not state moisture content and did not indicate whether Fe content was tested on wet or dry basis, whereas the authorised inspection report specifically recorded moisture content and was consistent with the assessment basis required by the governing law. The settled position and the CBIC circular required Fe content for export duty assessment of iron ore to be determined on WMT basis.

Conclusion: The rejection of the declared transaction value was not sustainable, and the assessment finalized on the basis of the authorised test report and invoice value was correct.

Final Conclusion: The impugned order was set aside and the appellant's assessment was restored with consequential relief.

Ratio Decidendi: Declared export transaction value cannot be rejected absent substantive evidence of extra consideration or other valid grounds, and Fe content for iron ore export assessment must be determined on Wet Metric Ton basis where that is the legally prescribed method.

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