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The CESTAT allowed the appeal, holding that the revenue authorities erred in rejecting the declared/transaction value of the imported goods without any justifiable basis. It relied on the Supreme Court's decision in Century Metal Recycling Pvt. Ltd., which held that declared valuation can be rejected only based on evidence meeting the criteria of 'certain reasons', and the opinion formed must be reasonable. Since the revenue did not establish that the parties were related, any extra money was exchanged, or the declared value was influenced by extraneous factors, the rejection of transaction value was unjustified and hit by non-fulfillment of Rule 12.
The CESTAT allowed the appeal, holding that the revenue authorities erred in rejecting the declared/transaction value of the imported goods without any justifiable basis. It relied on the Supreme Court's decision in Century Metal Recycling Pvt. Ltd., which held that declared valuation can be rejected only based on evidence meeting the criteria of 'certain reasons', and the opinion formed must be reasonable. Since the revenue did not establish that the parties were related, any extra money was exchanged, or the declared value was influenced by extraneous factors, the rejection of transaction value was unjustified and hit by non-fulfillment of Rule 12.
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