FOB vs CIF Valuation

In a nuanced ruling balancing valuation rigour with limitation discipline, the Tribunal upheld the legal requirement to load FOB value with freight and insurance under Rule 10(2) where costs are not ascertainable.

However, it struck down the entire demand on limitation, holding that disclosure in import documents negates suppression and that revenue-neutral situations dilute intent to evade.

The decision is a sharp reminder that valuation disputes cannot be retrofitted into extended limitation cases without demonstrable mens rea.