Customs valuation requires proof of undervaluation; invoice value stands unless corroborated evidence shows the price is not commercial.

Declared customs value cannot be rejected unless the Revenue proves undervaluation with positive, corroborated evidence showing that the invoice price is not the real commercial price. A special relationship, extra-commercial consideration, or a reliable comparison with identical or similar imports is required; mere suspicion, discrepancies, or an unverified earlier import is insufficient. On the record, there was no proof that the parties were not dealing at arm's length or that the supplier's price was not commercially real, so the invoice value had to be accepted for assessment.

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Issues: Whether the invoice value of the imported goods could be rejected and the assessable value enhanced in the absence of corroborated evidence of undervaluation.

Analysis: The burden to establish undervaluation lies on the Revenue. Rejection of the declared value requires proof that the apparent invoice price does not reflect the real commercial price, such as evidence of a special relationship, extra-commercial consideration, or reliable comparison with identical or similar imports. Mere suspicion arising from discrepancies, or reliance on an earlier import that was not shown to be identical or similar, is insufficient to discard the transaction value. The record did not establish that the parties were not dealing at arm's length or that the supplier's price was not commercially real.

Conclusion: The invoice value could not be rejected, and the assessable value had to be accepted on the basis of the price shown in the invoice.

Ratio Decidendi: Declared value in customs valuation cannot be dislodged unless undervaluation is proved by positive, corroborated evidence; suspicion or unverified comparison with other imports does not justify enhancement.

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