Declared transaction value cannot be rejected solely for a wrong country-of-origin entry when the invoice particulars remain verified and reliable.

Declared invoice value cannot be rejected merely because the bill of entry misstated the country of origin, where customs verification confirmed the manufacturer's Canadian address and no incorrect particulars in the invoice were shown. The document states that the transaction value remained reliable because the department failed to establish that the invoice was false or that the declared particulars were inaccurate. In those circumstances, re-determination of assessable value by comparison with similar goods under Rule 8 was not justified, and the declared value was accepted in favour of the assessee.

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Issues: Whether the declared invoice value could be rejected and the assessable value re-determined under Rule 8 of the Customs Rules on the ground that the importer had misstated the country of origin.

Analysis: The imported goods were accompanied by a manufacturer's invoice issued by a Canadian entity, and the verification undertaken by customs confirmed the correctness of the manufacturer's address. The misdescription in the bill of entry as to the country of origin did not, by itself, establish that the invoice was false or that the transaction value was unreliable. Since the department did not show that the invoice contained incorrect particulars, there was no basis to disregard the declared value merely because a wrong origin had been stated. In these circumstances, resort to a comparison with similar goods was not justified.

Conclusion: The invoice and declared transaction value were accepted, and the departmental challenge to the reassessment failed, in favour of the assessee.

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