Customs valuation of imported reflectors failed where Japanese comparison imports were not contemporaneous or shown to be identical goods.

The assessable value of imported reflectors could not be enhanced on the basis of invoices from Japan because the relied-upon imports were not shown to be contemporaneous. The goods under assessment were imported from Singapore with declared Singapore origin, and the mere use of the same brand name did not establish the same origin or manufacturer. Comparison with Japanese imports was therefore treated as an insufficient valuation basis, following the approach adopted in an earlier similar matter. The declared invoice value was not displaced, and the enhancement was held unjustified.

---

---

Issues: Whether the enhancement of the assessable value of imported reflectors on the basis of imports from Japan was justified.

Analysis: The declared invoice value was enhanced by relying on invoices relating to similar goods imported from Japan. The imports relied upon were not shown to be contemporaneous, and the goods were imported from Singapore with a declared Singapore origin. The mere fact that the goods bore the same brand name did not establish that they were of the same origin or from the same manufacturer. Following the approach adopted in an earlier similar matter, the comparison with imports from Japan was not treated as a sufficient basis for enhancement.

Conclusion: The enhancement of the assessable value was not justified and the appeal was allowed.

---