Acceptance of reassessed customs value does not bar statutory appeals where valuation safeguards were bypassed
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....Acceptance of reassessed customs value under protest does not extinguish the importer's independent statutory right to challenge the reassessment. Written acceptance relieves the proper officer of issuing a speaking order but does not create estoppel against statutory rights in taxation. Rejection of a declared transaction value requires written communication of the grounds for doubting its truth or accuracy. Enhanced valuation cannot rest solely on undisclosed alleged contemporaneous imports; the importer must receive the relevant comparable-import data and comparability particulars. Redetermination of value must follow the prescribed sequential valuation rules after the declared value is validly rejected.....
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