Customs undervaluation dispute: Transaction value rejected despite evidence; orders set aside for redetermination.

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....Dispute regarding valuation of imported goods under Customs Valuation Rules. Related parties involved, 10% loading applied to transaction value earlier. New Customs Valuation Rules 2007 introduced changes in Rules 3 and 12 regarding rejection of transaction value. Earlier order expired, cannot be relied upon. Authorities failed to provide cogent reasons for rejecting declared transaction value as per Section 14(1) and Rules 3, 12 of 2007 Rules. Impugned orders set aside, matter remanded to redetermine transaction value considering changed circumstances. Appellant provided evidence of third-party purchases at same price, negating mutuality of interest. Appropriate adjudication required considering relevant Customs Valuation Rules.....