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CESTAT allowed appeal challenging customs valuation of imported aluminum ingots between related parties. Revenue rejected declared transaction value based solely on LME prices without establishing higher contemporaneous import prices. CESTAT held transaction value under Section 14 Customs Act cannot be rejected absent evidence of contemporaneous imports at higher prices. LME prices alone insufficient to prove undervaluation when similar contemporaneous imports existed at comparable prices. SVB conducted detailed examination twice, accepting declared value after scrutinizing invoices and documents. Commissioner (Appeals) mechanically remanded matter without cogent reasons for rejecting assessable value. CESTAT found no evidence of flowback arrangements, royalty payments, or technical fees indicating price manipulation. Order-in-Appeal lacked methodology for alternative valuation determination. Revenue failed to demonstrate undervaluation through contemporaneous market evidence, rendering rejection of declared value legally unsustainable under established customs valuation principles.
CESTAT allowed appeal challenging customs valuation of imported aluminum ingots between related parties. Revenue rejected declared transaction value based solely on LME prices without establishing higher contemporaneous import prices. CESTAT held transaction value under Section 14 Customs Act cannot be rejected absent evidence of contemporaneous imports at higher prices. LME prices alone insufficient to prove undervaluation when similar contemporaneous imports existed at comparable prices. SVB conducted detailed examination twice, accepting declared value after scrutinizing invoices and documents. Commissioner (Appeals) mechanically remanded matter without cogent reasons for rejecting assessable value. CESTAT found no evidence of flowback arrangements, royalty payments, or technical fees indicating price manipulation. Order-in-Appeal lacked methodology for alternative valuation determination. Revenue failed to demonstrate undervaluation through contemporaneous market evidence, rendering rejection of declared value legally unsustainable under established customs valuation principles.
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