Declared transaction value in customs valuation stands unless fraud is proved; non-comparable imports cannot justify revaluation.

Customs valuation of imported Vitamin Mixes turned on the primacy of declared transaction value and the comparability of contemporaneous imports. The department could not displace the invoice value without evidence of fraud, collusion or over-valuation, and mere suspicion was insufficient. The Revenue's relied-upon import data was rejected because the goods differed materially in chemical composition and active vitamin concentration, making them non-comparable for valuation. By contrast, the importers' own contemporaneous import evidence was accepted because the allegation of staged or manipulated transaction was unsupported by proof. The departmental valuation therefore was not sustained.

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Issues: (i) Whether the declared transaction value of the imported Vitamin Mixes could be rejected under customs valuation law; (ii) whether the contemporaneous imports relied upon by the Revenue were comparable goods and could be used to determine value; (iii) whether the importers' relied-upon contemporaneous import evidence was acceptable in law.

Issue (i): Whether the declared transaction value of the imported Vitamin Mixes could be rejected under customs valuation law.

Analysis: The department produced no evidence of fraud, collusion, or over-valuation in the invoice or bill of entry. Rejection of the declared value could not rest on suspicion alone, and the burden to displace the transaction value lay on the department.

Conclusion: The declared transaction value could not be rejected.

Issue (ii): Whether the contemporaneous imports relied upon by the Revenue were comparable goods and could be used to determine value.

Analysis: The relied-upon imports had materially different chemical composition, especially in the concentration of active vitamins, and the difference was not marginal. Since value in such products depended on the active ingredients rather than fillers, the cited imports were not comparable goods for valuation purposes.

Conclusion: The Revenue's contemporaneous imports were not comparable and could not be used for valuation.

Issue (iii): Whether the importers' relied-upon contemporaneous import evidence was acceptable in law.

Analysis: The department's allegation that the importers' comparable import was a staged or associated transaction was unsupported by evidence. In the absence of proof of conspiracy or manipulation, the contemporaneous import evidence remained valid under customs valuation principles.

Conclusion: The importers' contemporaneous import evidence was acceptable in law.

Final Conclusion: The valuation adopted by the department was not sustained, and the orders in appeal were upheld, leaving the Revenue without relief.

Ratio Decidendi: Declared transaction value cannot be rejected without proof of fraud or collusion, and contemporaneous imports can be used for valuation only if they are truly comparable in material composition.

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