Transaction value for imported goods cannot be rejected without reliable comparable imports or corroborative evidence.

Declared transaction value for imported micro motors could not be rejected merely because the Department relied on alleged comparable imports of another importer. The goods were found to be different, and the evidence did not establish that the other imports were identical or truly comparable. Mere difference in classification was insufficient to displace the invoice price, and no corroborative material showed the declared value to be unreliable. On that basis, enhancement of assessable value was unsustainable, and the penalty based on the same valuation allegation could not be maintained.

---

---

Issues: Whether the assessable value of the imported micro motors could be enhanced by relying on the value of alleged similar imports of another importer, and whether the rejection of the declared value and consequential penalty were justified.

Analysis: The imported goods were found to be different from the goods relied upon by the Department for valuation. The evidence did not establish that the other imports were identical or truly comparable goods, and the declared invoice price was not shown to be unreliable. Mere difference in classification did not by itself justify rejection of the transaction value or enhancement of assessable value. In the absence of corroborative evidence to displace the declared value, the basis adopted by the Department for enhancement was unsustainable, and the penalty founded on the same allegation could not stand.

Conclusion: The enhancement of assessable value was not justified, the declared value was to be accepted, and the penalty was rightly set aside.

---