In thirty consolidated petitions — C.P.L.A.86-K to 115-K/2023 — the Collector of Customs, Appraisement (East), Karachi challenged the Sindh High Court's judgment of 16.11.2022 in a regulatory-duty and valuation dispute. The respondents were two sets of importers: M/s Forte Marketing Services, Lahore (petitions 86-K to 94-K) and M/s RAK Trading Marketing Services (95-K to 115-K). The question was which value the Customs could assess: the transaction value under section 25(1) of the Customs Act, or the value under the Valuation Ruling then in force.
On 24.09.2026, a bench headed by Chief Justice Yahya Afridi — judgment authored by Mr. Justice Muhammad Shafi Siddiqui, with Mr. Justice Miangul Hassan Aurangzeb — converted the petitions into appeals, allowed them, and set aside the High Court's judgment. The holding: Valuation Ruling No.874 of 2016 dated 22.06.2016 was in force at the time of assessment, and a live Valuation Ruling precludes resort to the transaction value under section 25(1) merely because 90 days had lapsed.
The principle disciplines valuation disputes. Valuation Rulings are the department's notified fallback precisely for situations where declared transaction values are suspect; importers cannot bypass a live ruling by pointing to the calendar. Ninety days' passage does not kill a ruling that the department has kept alive — the ruling governs until replaced or withdrawn.
For importers and clearing agents, the compliance lesson is to check the ruling book before the invoice book: agar Valuation Ruling zinda hai, to transaction value ki dalil nahi chalegi. And for the Customs, a validation — assessments anchored in a live ruling will survive appellate scrutiny.