Imported machine valuation turns on reliable comparable evidence, with reassessment made on invoice value and reduced redemption fine.

Imported machine valuation could not safely be based on an alleged United Kingdom comparable because the record did not show that the machines were identical or sufficiently similar in specification, origin, size, brand, or date of import. At the same time, the importer's documents were incomplete and did not satisfactorily explain the gap between the purchase documents and the declared invoice value. The proper course was to reassess the value on the basis of the Hong Kong invoice value rather than the United Kingdom price, and the redemption fine was reduced accordingly.

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Issues: Whether the assessable value of the imported machine should be determined on the basis of the appellant's invoice and cash memo or on the basis of the alleged comparable United Kingdom price, and whether the redemption fine required reduction.

Analysis: The documents produced by the appellant did not give complete particulars of the machine, but the order adopting the United Kingdom price as the benchmark also lacked material particulars showing that the two machines were identical or sufficiently similar in specification, origin, size, brand, or date of import. On that footing, the foreign comparable could not safely be used as the basis for valuation. At the same time, the appellant did not establish that the machine was an old one or provide a satisfactory explanation for the substantial difference between the purchase documents relied upon and the invoice value. The appropriate course was therefore to reassess value on the basis of the Hong Kong invoice value rather than the United Kingdom price, with consequential reduction of the redemption fine.

Conclusion: The assessable value was taken at Hong Kong $ 15,600 FOB and the redemption fine was reduced to Rs. 10,000, with the appellant succeeding only to that extent.

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