Customs valuation requires objective comparable evidence before rejecting declared transaction value and enhancing import value.

Transaction value under customs valuation cannot be rejected unless the authority establishes valid grounds on objective, comparable material. A higher price from another import is insufficient where the comparison lacks particulars on quantity, commercial level, country of origin and grade, and where the importer's invoice and supporting documents are not properly addressed. In the absence of technical literature, test reports or reliable market data showing that the goods were of a standard variety warranting enhancement, rejection of the declared value is unsustainable. The enhanced assessable value was therefore not maintainable and the declared transaction value stood accepted.

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Issues: Whether the enhancement of the declared import value of Patchouli Oil and rejection of the transaction value were justified under the customs valuation provisions.

Analysis: The declared price could not be discarded merely because a higher recorded price in another import was available. The comparable import relied upon by the lower authority lacked particulars showing similarity in quantity, commercial level, country of origin, and grade. The importer's invoice and supporting material were not properly dealt with, and no technical literature, test report, or reliable market data was produced to establish that the goods were of the standard variety or that the declared grade SL/8 warranted enhancement. In the absence of proper grounds and objective supporting material, rejection of the transaction value was held to be unsustainable.

Conclusion: The enhancement of value was not maintainable and the declared transaction value could not be rejected on the material relied upon by the lower authority.

Final Conclusion: The appeal succeeded and the order enhancing the assessable value was set aside.

Ratio Decidendi: Transaction value cannot be rejected for customs valuation purposes unless the authority establishes, on objective and comparable material, valid grounds for discarding the declared price.

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