Acceptance of enhanced customs value under protest to secure...

Acceptance of enhanced customs value under protest to secure clearance and avoid demurrage does not bar an appeal, as taxation matters do not apply estoppel on that basis. Folded and stitched polyester woven printed quilt covers must be classified in their imported condition as ready-to-use made-up textile articles, rather than as bed sheets obtainable only after de-stitching. Declared transaction value cannot be rejected merely by comparison with non-comparable bed-sheet imports; objective evidence creating reasonable doubt is required. Because neither misclassification nor undervaluation was established, confiscation, redemption fine and penalty lacked a basis; redemption fine also required market-price determination.