Transaction value reassessment requires cogent evidence; valuation guidelines alone cannot displace declared import values or sustain consequential demands.

Finally assessed transaction value of imported aluminium scrap cannot be rejected and reassessed solely on Directorate of Valuation guidelines based on London Metal Exchange prices. Rejection under the Customs Valuation Rules requires objectively reasonable doubt, recorded reasons and cogent material establishing that the declared value is incorrect. Benchmark data or guidelines without independent evidence discrediting supplier invoices or the transaction value cannot support reassessment. As the earlier assessments had not been challenged, the reassessment-based demand, interest and penalty were unsustainable.

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Issues: Whether a finally assessed transaction value of imported aluminium scrap can subsequently be rejected and reassessed solely on Directorate of Valuation guidelines based on London Metal Exchange prices.

Analysis: The Bills of Entry had been assessed after scrutiny, and in some instances the value had already been enhanced. The Department had not challenged those assessments. Rejection of the declared transaction value under the valuation framework requires objectively reasonable doubt supported by recorded reasons and cogent material showing that the declared value is incorrect. Directorate of Valuation guidelines lack statutory force and cannot override the Customs Valuation Rules. Reliance only on benchmark data or London Metal Exchange-based guidelines, without independent evidence discrediting the supplier invoices or transaction value, could not justify a subsequent reassessment.

Conclusion: The declared transaction value could not be rejected or reassessed on the sole basis of the Directorate of Valuation guidelines; the demand, interest and penalty founded on that reassessment were unsustainable, in favour of the assessee.

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