Past Bills of Entry could not be reopened for enhancement of...

Past Bills of Entry could not be reopened for enhancement of value once the consignments had been cleared and were no longer available for examination; later email copies and statements, without verification of quantity and quality, were insufficient to sustain undervaluation. The differential duty on those past imports was therefore set aside. For the live Bill of Entry, the Tribunal found sufficient evidence of undervaluation from the examination report, bank documents and recovered email correspondence showing inconsistencies in value, description and invoice details, and upheld rejection of the declared value and the duty demand. Because duty and interest had already been paid and no item-wise details were produced, the redemption fine and penalty were reduced.