Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent authorities.

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....Customs valuation rules permit rejection of a declared transaction value where higher National Import Database values for contemporaneous identical goods give reasonable doubt as to its truth or accuracy. Comparable imports must be at the same commercial level, in comparable quantities and from the same country of origin; the lowest comparable value may be adopted. An importer's earlier self-assessed import does not displace such comparables where product specifications are absent from invoices and packing lists. Failure to issue a speaking assessment order does not itself invalidate the assessment where the importer may seek issuance of that order from the competent authorities.....