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In export valuation under Section 14, the transaction value is the primary measure and Customs Valuation Rules (CVR, 2007) must be applied sequentially; the Revenue bears the burden to displace a declared invoice value. The tribunal found the department bypassed the sequential Rules and improperly relied on a market survey that compared manufacturers' prices to a trader's procurement cost, rendering the comparison and re-determined per unit valuation (with an added notional 10% profit) incorrect and unsupported by law. Because the Revenue failed to justify reassessment, the appeals were dismissed and the seized goods were directed to be released following upload of the order.
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