Rule 12 implies recording reasons for rejecting declared values in imported goods valuation; applies prospectively, not retroactively.

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....Valuation of imported goods - rejection of declared value - The mandate to record reasons at the second stage of enquiry is not expressly stipulated, albeit it has been read by us by implication in Rule 12 - mandate if applied to past cases would possibly lead to complications and difficulties - decision will be applicable prospective - past cases will be decided on a case to case basis....