Customs valuation requires cogent evidence before rejecting invoice value; a bare higher price list is not enough.

Declared invoice value for imported machinery could not be rejected merely because customs authorities referred to a higher price list in departmental records. Under section 14(1)(a) of the Customs Act, the assessable value must reflect the price ordinarily obtainable at the time and place of importation, and rejection of the invoice price requires cogent evidence that it is not genuine. Here, the department did not place the relied-on price list on record, undertook no verification, and produced no evidence of contemporaneous higher imports or any special relationship or extra consideration. The supplier's price list, trade discount and supporting correspondence justified acceptance of the declared value.

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Issues: Whether the declared invoice price of the imported flour milling machinery could be rejected and the assessable value enhanced on the basis of a higher price list said to be available with the customs authorities, and whether the evidence of trade discount and supplier correspondence justified acceptance of the invoice value.

Analysis: Under section 14(1)(a) of the Customs Act, 1962, the assessable value is the deemed value of goods ordinarily sold or offered for sale at the time and place of importation. The rejection of the invoice price cannot rest merely on a higher price said to be available in departmental records, particularly when the price list relied upon by the department was not placed on record and no investigation was undertaken to test the genuineness of the declared price. The appellants produced their suppliers' price list showing a special trade discount and additional correspondence explaining the reduction in price. There was also no evidence of contemporaneous imports of identical goods at a higher price or of any special relationship or extra consideration rendering the declared price doubtful. In these circumstances, the invoice price could not be discarded straightaway.

Conclusion: The rejection of the declared invoice value was not justified, and the assessable value could not be enhanced on the material available.

Ratio Decidendi: A declared import price may be rejected under section 14(1)(a) of the Customs Act, 1962 only on the basis of cogent evidence showing that it does not represent the price ordinarily obtainable in international trade at the time and place of importation; a bare higher price list or untested departmental doubt is insufficient.

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