Export valuation must rest on declared transaction value unless reasons and evidence justify rejection of the invoice price.

Declared export transaction value cannot be rejected and replaced with a higher contemporaneous value unless the proper valuation procedure is followed and cogent reasons are recorded for doubting the declared price. Where the invoice value is supported by the contract and bank realisation particulars, and no prior doubt about truth or accuracy is shown, mere reference to selected contemporaneous prices is insufficient to displace the transaction value. The declared value therefore remained the relevant basis for assessment, and reconsideration had to proceed in line with the bank realisation statement.

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Issues: Whether the declared export transaction value could be rejected and substituted with a higher contemporaneous value without recording cogent reasons and following the prescribed valuation procedure.

Analysis: The assessment dispute related only to the unit price declared for export goods. The declared price was discarded by adopting the highest contemporaneous price, even though the record did not show any prior doubt about the declared value or the bank realisation particulars. The valuation framework requires acceptance of the transaction value unless there are valid reasons to doubt its truth or accuracy, and rejection must be supported by reasons and material evidence. In the absence of such reasons, and where the invoice value stood corroborated by the contract and bank realisation, the declared value could not be displaced merely by reference to selected contemporaneous prices.

Conclusion: The rejection of the declared export value was not sustainable, and the matter had to be reconsidered in accordance with the transaction value reflected in the bank realisation statement.

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