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The Appellate Tribunal CESTAT, Mumbai ruled that values declared on the Bill of Entry must align with transaction value, considering evidence of contemporaneous imports. The imports were for defective/stock lot from European countries, with authorities using prime quality goods for comparison and offering arbitrary discounts. The Commissioner (Appeals) rejected the declared value enhancement agreed upon during a hearing, stating that transaction value can only be departed from based on records and Valuation Rules. The appellants' reliance on Supreme Court decisions in Basant Industries and Eicher Tractors Ltd. was upheld, leading to the appeals being allowed and the previous order set aside.
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