Imported goods valuation must rest on comparable goods of the same origin, not different-country price references.

Imported projector lenses of Singapore origin could not be revalued by reference to prices of similar Japanese-origin goods, because the Department failed to produce reliable evidence of the value of comparable goods of the same origin and did not show the Singapore-origin declaration to be false or bogus. On that record, the enhancement of assessable value was unjustified and the differential duty demand could not be sustained. The separate exemption-notification question did not require decision once the valuation issue was resolved.

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Issues: Whether the value of imported projector lenses of Singapore origin could be enhanced by relying on prices of similar goods of Japanese origin, and whether the differential duty demand could be sustained on that basis.

Analysis: The goods declared in the Bill of Entry were accepted as of Singapore origin, and the Department did not establish that declaration to be false or bogus in the show cause notice. The materials relied upon by the Department related to projector lenses of Japanese origin, although of the same brand, and no evidence was produced of higher prices for projector lenses of Singapore origin. In the absence of comparable evidence for goods of the same origin, the prices of Japanese-origin goods could not be used to load the value of the imported Singapore-origin goods. The alternative question regarding exemption notification did not require decision once the valuation issue was resolved.

Conclusion: The enhancement of value was unjustified and the demand of differential duty could not be sustained.

Ratio Decidendi: Imported goods cannot be revalued on the basis of prices of comparable goods of a different country of origin unless the Department establishes reliable evidence of the value of goods of the same origin.

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