Customs valuation requires reliable contemporaneous import evidence before rejecting declared value of ball bearings.

Under customs valuation rules, the declared invoice value of imported ball bearings must be accepted unless the revenue shows it is unacceptable through reliable evidence of identical or similar goods imported proximate in time, from the same source, and in comparable quantities. Manufacturer price lists and quotations were insufficient because they did not clearly identify the source, applicability period, manufacturer identity, or a proper basis for comparison with the imported goods. As contemporaneous imports at the enhanced values were not proved, the burden of establishing undervaluation was not discharged and resort to a later valuation method was not justified. The enhancement of value was therefore not sustained.

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Issues: Whether the declared import value of the ball bearings could be rejected and enhanced on the basis of price lists and alleged contemporaneous imports.

Analysis: Under the valuation rules, the invoice value is to be accepted unless it is shown to be unacceptable, and any departure must rest on reliable evidence of identical or similar goods imported proximate in time, from the same source, and in comparable quantities. The department relied on manufacturer price lists and quotations that did not clearly disclose the source, applicability period, manufacturer identity, or the basis on which the prices could be matched with the imported goods. The evidence did not establish contemporaneous imports at the enhanced values, and the burden to prove undervaluation remained on the revenue. In the absence of such proof, recourse to the later valuation method was not justified.

Conclusion: The enhancement of value was not sustained and the appeal was allowed in favour of the assessee.

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