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As per the case facts, the Commissioner of Customs appealed a decision by the Customs, Excise and Service Tax Appellate Tribunal (CESTAT). The dispute centered on whether the customs authorities
...were justified in increasing the value of imported goods and imposing penalties, based on allegations of under-invoicing tuners from Hong Kong. Information suggested these goods were imported at significantly lower prices than their actual value, leading to customs duty evasion. CESTAT had previously ruled against the customs authorities, setting aside the value enhancement and penalties. The question arose whether CESTAT was correct in concluding that the increased value of the imported goods and the penalties imposed by the customs authorities were unsustainable. Finally, the Supreme Court upheld CESTAT's judgment, dismissing the customs department's appeals. The Court found that both the department and the adjudicating authority were not justified in rejecting the declared import price and increasing it by directly applying a specific rule of the Customs Valuation Rules without sufficient evidence.
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