Customs valuation by reasonable method upheld where import description was incomplete and invoice value lost transaction-value sanctity.

Declared invoice value may be rejected where import documents contain only a bald and incomplete description of the goods and omit particulars material to quality and value, because the invoice price then loses its normal sanctity as transaction value. Although the burden ordinarily lies on the Department to displace invoice value, inadequate or misleading description permits valuation by a reasonably reliable method to ascertain ordinary international price. In the absence of comparable contemporaneous imports, valuation based on brass scrap prices with added manufacturing cost was upheld as reasonable on the facts, and the record also supported deliberate misdeclaration, justifying confiscation, redemption fine, and penalty.

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Issues: Whether the declared invoice value of the imported brass chain could be accepted for assessment, and whether the consequent confiscation, redemption fine, and penalty were justified.

Analysis: The import documents gave only a bald and incomplete description of the goods, without specification, design, number, or other particulars that were material to quality and value. In such circumstances, the invoice price did not retain its normal sanctity as transaction value. The burden to displace invoice value ordinarily lies on the Department, but where the description is deliberately inadequate or misleading, the question is to ascertain the ordinary international price by a reasonably reliable method. No comparable contemporaneous imports were shown. The valuation adopted by reference to brass scrap prices and an added manufacturing cost was held to be a reasonable method on the facts. The record also supported a finding of deliberate misdeclaration.

Conclusion: The declared value was rightly rejected, the enhanced valuation was upheld, and the confiscation, redemption fine, and penalty were sustained against the assessee.

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