Customs valuation may follow certified manufacturer export price where reliable evidence identifies the imported vehicle precisely.

Reliable additional evidence was admitted where it was relevant and assisted in determining the correct customs value of the imported vehicle. The chassis number in the manufacturer's communication matched the car covered by the bill of entry, and the department's reliance on an inferior model invoice was rejected when the relevant catalogue was unavailable. On that basis, the certified FOB export price supplied by the manufacturer was accepted as the proper assessable value, requiring reassessment of the car and any consequential refund due.

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Issues: (i) Whether the additional evidence sought to be produced under Rule 23 of the CEGAT (Procedure) Rules should be admitted. (ii) Whether the assessable value of the imported car should be determined on the basis of the manufacturer's certified export price rather than the department's adopted value.

Issue (i): Whether the additional evidence sought to be produced under Rule 23 of the CEGAT (Procedure) Rules should be admitted.

Analysis: The document produced through the Indian Embassy in Japan was treated as reliable and relevant for deciding the dispute. The Tribunal found that its contents would assist in determining the correct value of the imported vehicle.

Conclusion: The additional evidence was admitted.

Issue (ii): Whether the assessable value of the imported car should be determined on the basis of the manufacturer's certified export price rather than the department's adopted value.

Analysis: The chassis number in the manufacturer's communication matched the vehicle covered by the bill of entry. The department had relied on the invoice of a superior model when the relevant world car catalogue was unavailable. In these circumstances, the certified FOB export price of the imported vehicle was accepted as the proper basis for valuation.

Conclusion: The assessable value had to be reworked on the basis of the manufacturer's certified export price, with consequential refund if due.

Final Conclusion: The valuation adopted by the lower authority was set aside and the imported car was directed to be reassessed on the certified export price basis, resulting in relief to the importer.

Ratio Decidendi: Where reliable manufacturer certification identifies the very vehicle imported and the department's comparable model basis is inferior or unsupported, the certified export price may be adopted for customs valuation.

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