Customs valuation requires reasoned rejection of declared value; comparison with another import was insufficient without proper contemporaneity and goods analysis.

Customs valuation under Section 14 of the Customs Act, 1962 must follow the 1988 Valuation Rules, and transaction value can be displaced only on legally sustainable grounds. A declared import value was rejected mainly by comparing it with another import, but the record did not show a reasoned examination of comparable imports, the identity of the goods, differences in attachments, or whether the imports were truly contemporaneous. The adjudication order also failed to deal properly with the relevant documents or give adequate reasons on the material valuation factors. On that reasoning, the rejection of the declared value could not be sustained and the matter was remitted for fresh adjudication.

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Issues: Whether the declared value of the imported machine could be rejected under the Customs valuation rules on the basis of another import and whether the adjudication order disclosed proper reasoning.

Analysis: The valuation of imported goods under Section 14 of the Customs Act, 1962 must conform to the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988, and the transaction value can be displaced only on legally sustainable grounds. In the present case, the rejection of the declared value rested substantially on comparison with another import, but the record did not show a reasoned examination of the appellant's reliance on other comparable imports, the identity of the goods, the differences in attachments, or whether the imports were truly contemporaneous. The order also failed to deal adequately with the relevant documents and did not contain a reasoned finding on the material aspects governing valuation.

Conclusion: The declared value could not be sustained as rejected on the basis of the impugned reasoning, and the order was liable to be set aside with the matter remitted for fresh adjudication.

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