The Supreme Court held that customs authorities cannot enhance valuation solely on unverified export declarations. The decision reinforces evidentiary standards in customs proceedings.
Customs Valuation Cannot Be Based on Unproved Export Declarations
In a significant ruling, the Supreme Court has held that the customs valuation of imported goods cannot be enhanced based on unproved or unsubstantiated export declarations from foreign suppliers. The Court emphasized that assumptions without corroborative evidence violate principles of natural justice and the scheme of the Customs Act, 1962.
The decision arises from a challenge to a valuation order where the customs authorities relied on export declarations from abroad that were neither verified nor authenticated. The Court observed that such documents, if not properly proved under the Bharatiya Sakshya Adhiniyam, 2023 (BSA), cannot form the basis for adverse action.
"Reasonable opportunity of being heard and reliance on authentic evidence are foundational to fair administrative action,"the Court held.
This judgment strengthens the protection against arbitrary customs assessments and underscores the need for evidence-based decision-making. Practitioners must ensure all foreign-origin documents are authenticated under Section 63 BSA (equivalent to Section 65B Evidence Act) before reliance.
Citations
- Commissioner of Customs v. M/s. Global Traders (2026) SCC OnLine SC
