Second-hand machinery valuation requires true comparability before rejecting declared value and enhancing import price.

Declared value of second-hand imported machinery cannot be rejected merely because another machine of the same make and year was imported at a higher CIF price. For valuation to be enhanced on a comparable-import basis, the department must show that the relied-upon machine was truly comparable in condition, extent of use, residual life and state at the time of importation. A Chartered Engineer's certificate may support the value of a new machine of the same kind, but it does not by itself justify rejection of the declared value of used machinery. Depreciation guidance for second-hand machinery was treated as a proper basis for valuation, and the allegation of undervaluation was not established.

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Issues: Whether the declared value of the imported second-hand printing machine could be rejected and enhanced on the basis of a comparable import without proof that the two machines were comparable in condition, extent of use, residual life and state at the time of importation.

Analysis: The declared value was rejected because another machine of the same make and year had earlier been imported at a higher CIF price. The Chartered Engineer's certificate was found not to establish the value of the machine, but it did support the value of a new machine of the same kind. For second-hand machinery, mere similarity in make and year is insufficient. The department was required to show that the relied-upon import was a fair comparison in terms of use, condition and residual life. No such material was produced. The appellant's reliance on depreciation guidance for second-hand machinery was also found to be a proper recourse, not a basis for rejection.

Conclusion: The charge of undervaluation was not established and the enhancement of value could not be sustained.

Ratio Decidendi: In valuation of second-hand imported machinery, the department must prove that the comparable relied upon is truly comparable in condition, use and residual life before rejecting the declared value.

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