Transaction value in import valuation cannot be rejected without reliable comparables or proper factual basis for undervaluation.

Declared transaction value for imported disperse dyes should not be displaced without reliable factual material showing undervaluation or valid comparables. The record did not adequately support rejection of the origin certificate merely because no Indonesian certificate was produced, and goods of German origin could not be treated as identical or similar to goods of Indonesian origin without dependable comparative data. The valuation rules required a proper basis before adopting a higher assessable value, so the enhanced valuation and consequential confiscation, duty demand, redemption fine and penalty could not stand.

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Issues: Whether the declared transaction value of imported disperse dyes could be rejected and a higher assessable value adopted on the basis of comparable prices of goods of a different country of origin.

Analysis: The declared goods were unbranded and the importer had not disclosed certain particulars such as index number and strength, but the record did not establish that this alone justified rejection of the transaction value. The finding that the goods were not of Indonesian origin was not supported by adequate material, and the origin certificate from the Singapore Chamber of Commerce could not be rejected merely because no certificate from Indonesia was produced. For valuation, goods of German origin could not be treated as identical or similar to goods of Indonesian origin without reliable comparative data. The valuation rules required a proper factual basis before the declared value could be displaced, and no sufficient material was brought to show comparable international prices for goods of the same origin.

Conclusion: The rejection of the transaction value was not sustainable, and the enhanced assessable value and consequential confiscation, duty demand, redemption fine and penalty could not stand.

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