Customs valuation requires reliable corroboration; a retracted statement and non-comparable invoice cannot justify enhancement of declared value.

A declared import value cannot be rejected or enhanced on the basis of a promptly retracted statement alone. The comparison invoice was not a valid benchmark because its description and specifications differed from the imported goods, and there was no supporting evidence of contemporaneous imports to justify rejection of transaction value under Rule 12 of the Customs Valuation Rules or redetermination under Rule 3(1) read with Section 14 of the Customs Act. The enhancement and consequential findings based solely on the retracted statement were therefore unsustainable, and the impugned order was set aside.

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Issues: Whether the rejection of the declared customs value and its enhancement on the basis of a retracted statement and an allegedly comparable invoice was sustainable.

Analysis: The assessment was founded essentially on a statement recorded under Section 108 of the Customs Act, 1962, which had been promptly retracted. The material relied upon for comparison was found not to be comparable, since the invoice description and specifications of the cited goods differed from the imported goods. No supporting evidence or discussion of contemporaneous imports was available on record to justify rejection of the declared transaction value under Rule 12 of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007 or its redetermination under Rule 3(1) of those Rules read with Section 14 of the Customs Act, 1962.

Conclusion: The enhancement of value and the consequential findings based solely on the retracted statement could not be sustained; the impugned order was set aside.

Ratio Decidendi: A declared import value cannot be rejected or enhanced merely on the basis of a retracted statement without reliable corroborative evidence, including valid contemporaneous comparable imports.

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