Rejection of a declared customs transaction value requires...

Rejection of a declared customs transaction value requires recorded and communicated reasonable doubt and cannot rest solely on acceptance letters or uncorroborated contemporaneous-import data. Comparable-import valuation must establish relevant comparability factors, including quality, quantity, GSM and timing. Written acceptance of reassessment can dispense with a speaking order but does not waive the importer's statutory right to challenge the formation of opinion or the reassessment on merits. Enhanced valuation based only on acceptance letters and unsupported import data therefore lacks a lawful basis, and the importer may contest it despite written acceptance.