JUSTICE DILIP GUPTA:

This appeal seeks to assail the order dated December 03, 2020 passed by the Commissioner of Customs (Appeals), the Commissioner (Appeals) that rejects the appeal filed by the appellant against the order dated March 18, 2019 passed by the Additional Commissioner by which 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 and re-determined under rule 3.

2. An investigation was conducted by the Directorate of Revenue Intelligence regarding undervaluation in imports of furniture and furniture parts. It was believed that large number of importers had formed a cartel and indulged in large scale evasion of customs duty by undervaluation and mis-declaration of the goods. The allegations of mis-declaration and undervaluation of furniture and furniture parts was based mainly on the printouts of emails and statements of persons recorded under section 108 of the Customs Act.

3. It would, therefore, have to be seen whether the statements recorded under section 108 of the Customs Act can be considered as relevant