Declared customs value requires comparable evidence and procedural fairness before rejection under the valuation rules.

Declared customs value may be rejected only when the proper officer has reasonable doubt supported by relevant comparable evidence of identical or similar imports at or about the same time and in comparable quantities, and the importer is first given disclosure of the basis and an opportunity to explain before sequential valuation is applied. Reassessment based essentially on a single import reference and NIDB data, without adequate supporting material or disclosure, was found unsustainable. The prior decision in the importer's own case under the same valuation framework was followed, and the rejection of declared value with consequent reassessment was set aside.

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Issues: Whether the rejection of the declared transaction value of imported goods and reassessment of customs duty on the basis of a single contemporaneous import value and NIDB data was sustainable under the Customs Valuation Rules, 2007.

Analysis: The declared value can be rejected only when the proper officer has reasonable doubt supported by material showing significantly higher values of identical or similar goods imported at or about the same time in comparable quantities and transactions. The doubt must be founded on reasons recorded and communicated, and the importer must be afforded an opportunity to furnish further information before resorting to sequential valuation. On the facts, the reassessment rested on insufficient supporting material, with reliance essentially on one import reference and without adequate disclosure of the basis for comparison. The earlier decision in the appellant's own case, applying the same statutory framework, was followed.

Conclusion: The rejection of the declared value and the consequent reassessment were unsustainable. The appeal was allowed and the impugned order was set aside.

Ratio Decidendi: Declared customs value cannot be rejected unless the department establishes reasonable doubt with relevant comparable evidence and follows the mandatory procedure of disclosure and opportunity before applying sequential valuation under the valuation rules.

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