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Written acceptance of an enhanced customs assessable value does not waive an importer's statutory right to challenge reassessment; it may only dispense with the proper officer's obligation to issue a speaking order. Rule 12(2) requires the proper officer to form and communicate written grounds for reasonable doubt before rejecting the declared transaction value. Acceptance letters lacking particulars of alleged contemporaneous imports do not meet that requirement. NIDB data alone, without independent and cogent supporting material, cannot sustain rejection of declared value or enhancement. The enhanced values and appellate orders were unsustainable, and the appeals succeeded with consequential relief.
Written acceptance of an enhanced customs assessable value does not waive an importer's statutory right to challenge reassessment; it may only dispense with the proper officer's obligation to issue a speaking order. Rule 12(2) requires the proper officer to form and communicate written grounds for reasonable doubt before rejecting the declared transaction value. Acceptance letters lacking particulars of alleged contemporaneous imports do not meet that requirement. NIDB data alone, without independent and cogent supporting material, cannot sustain rejection of declared value or enhancement. The enhanced values and appellate orders were unsustainable, and the appeals succeeded with consequential relief.
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TaxTMI 
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