Declared transaction value prevails in customs valuation unless reasonable doubt is first recorded under the valuation rules.

Customs valuation must start from the declared transaction value, and it may be rejected only where the proper officer records reasonable doubt about its truth or accuracy under Rule 12 before moving sequentially to alternative methods. Where imported goods were supported by invoice and banking documents, and the Department relied mainly on a later isolated comparison without first displacing the declared value on cogent grounds, enhancement of assessable value was unsustainable. The duty and interest paid under protest were treated as not lawfully payable, and refund with applicable interest followed.

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Issues: Whether the enhancement of the assessable value of imported goods was sustainable when the declared transaction value was supported by invoice and banking documents, and whether the duty and interest paid under protest were refundable with interest.

Analysis: Section 14(1) of the Customs Act, 1962 gives primacy to transaction value for imported goods. Under Rule 3(1) and Rule 3(2) of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007, the declared value must be accepted unless there are valid grounds to reject it. Rule 12 requires the proper officer to have reasonable doubt about the truth or accuracy of the declared value before moving sequentially through the valuation rules. The recorded facts showed invoice support, banking remittances, and comparable earlier imports near the declared rate, while the Department relied mainly on a later and isolated comparative entry without first discarding the transaction value on cogent grounds. The enhancement was therefore held to be contrary to the statutory valuation sequence, and the amount paid under protest was treated as not lawfully payable.

Conclusion: The enhancement of assessable value was unsustainable. The duty and interest paid under protest were held refundable with applicable interest.

Final Conclusion: The appeal succeeded, the enhanced valuation was set aside, and consequential refund relief with interest followed.

Ratio Decidendi: Customs valuation must proceed from the declared transaction value, and it can be rejected only on recorded reasonable doubt under Rule 12 before resorting sequentially to the alternative valuation methods.

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