JUSTICE DILIP GUPTA:

All these three appeals seek quashing of the order dated December 15, 2023 passed by the Principal Commissioner of Customs. The declared value of the goods has been rejected under rule 12 of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007 , the 2007 Valuation Rules read with section 14 of the Customs Act, 1962 , the Customs Act and re-determined under rule 3. Penalties under section 112(a)(ii) and section 114AA have been imposed upon the appellants.

2. The dispute is in respect of the 66 Bills of Entry that were filed during the period from April 2016 to November 2016 relating to furniture and furniture parts that were imported. The allegation of mis-declaration and under-valuation of furniture and furniture parts is based on the printouts of original invoices recovered from the email and various statements, including that of the supplier made under section 108 of the Customs Act.

3. The appeals were heard on two issues relating to the applicability of section 138B and section 138C of the Customs Act.

Section 138B of the Customs Act

4. The Principal Commissioner has relied upon statements made by the appellants under section 108 of th