What is a valuation ruling under section 25A, and how do I challenge one under section 25D?

Section 25 of the Customs Act, 1969 sets out how the customs value of goods is normally worked out. Section 25A lets the Directorate of Customs Valuation set that value directly for a type of goods, and once it does, customs assesses your consignment at that figure rather than at your invoice. Section 25D is the first route to contest it.

What does the law say about a valuation ruling?

The Act does not use the phrase “valuation ruling” in section 25A itself, but section 81 refers to “a Valuation Ruling (VR) or a Publication Valuation Ruling (PVR), issued under section 25A”, so the term is the Act’s own.

Section 25A(1) allows the Director of Customs Valuation, on his own motion, on a reference by any person or on a reference by an officer of Customs, to determine the customs value of any goods or category of goods imported into or exported out of Pakistan. He must follow the methods in section 25, whichever is applicable. The proviso lets him consult prices in internationally acclaimed publications, periodicals, bulletins or official websites of manufacturers.

Section 25A(2) makes that value “the applicable customs value for assessment”. Its proviso protects one direction only: if the value in your goods declaration, or in the invoice retrieved from the consignment, is higher than the determined value, the higher value is used.

Section 25A(2A) says that where determinations under sub-section (1) conflict, the Director General of Valuation decides the applicable value. Section 25A(4) says the value stays applicable “until and unless revised or rescinded by the competent authority”.

How do I challenge a valuation ruling?

Step 1: review under section 25D. The Director General Valuation may, on his own motion or on a review petition, rescind the value or determine it afresh. The petition must be made “within thirty days from the date of determination”, and it can be filed by “any person or an officer of Customs”. The proviso requires the proceedings to be completed within sixty days of the petition being filed, or of the Director General starting them himself.

Step 2: appeal to the Appellate Tribunal. Section 194A(1)(d) lists “an order passed in revision by the Director General Customs Valuation under section 25D” among the orders that can be appealed. The proviso to clause (d) says the appeal is heard by a special bench of at least two members, one Judicial Member and one Technical Member.

Section 194A(2) requires the appeal within forty-five days of the date the order is communicated. Under section 194A(3) a person other than a customs officer pays a fee of Rs. 20,000 for a company and Rs. 5,000 otherwise. Section 194A(4) lets the Tribunal admit a late appeal if it is satisfied there was sufficient cause.

What happens to my goods while I challenge it?

The ruling still applies. Section 81 deals with provisional assessment, where duty is fixed provisionally pending a test or inquiry. Its third proviso says no provisional determination of value is allowed where a Valuation Ruling or Publication Valuation Ruling issued under section 25A is in field, “irrespective of the fact whether any review or revision against such Valuation Ruling … is pending in terms of section 25D”. A pending review does not by itself let you clear at your invoice value.

At the Tribunal stage, section 194A(5) says the assessed amount remains payable unless the Tribunal stays recovery. A stay can first be granted for thirty days and cannot exceed ninety days in total, and the second proviso requires a pay order or bank guarantee of not less than twenty-five per cent of the principal amount.

Worked example (illustrative figures)

Sana imports kitchen appliances into Karachi. A ruling under section 25A covering her category of goods is dated 3 March.

1. Review deadline. Thirty days from 3 March is 2 April. She files a review petition with the Director General Valuation on 25 March.
2. Decision deadline. Sixty days from 25 March is 24 May (6 days to 31 March, 30 in April, 24 in May).
3. Tribunal deadline. The Director General’s order is communicated to her on 30 May. Forty-five days from 30 May is 14 July (1 day to 31 May, 30 in June, 14 in July).

On value: her invoice for one consignment shows Rs. 2,000,000, while the ruling’s figure for the same goods works out to Rs. 2,600,000. Customs assesses at Rs. 2,600,000. If her invoice had shown Rs. 2,800,000, the proviso to section 25A(2) would make Rs. 2,800,000 the customs value.

The duty on either figure depends on the tariff rate for her goods, which is not held in this corpus, so no duty amount is given here.

What if the Director General does not decide within sixty days?

The proviso to section 25D says the proceedings “shall be completed within sixty days”. The section does not say what follows if that limit is missed. This page does not resolve that question.

Common mistakes

• Waiting for a consignment to arrive before acting. The thirty days in section 25D run from the date of determination, not from the date your goods are assessed.
• Assuming a pending review allows provisional clearance at invoice value. The third proviso to section 81 rules this out where a ruling is in field.
• Going straight to the Collector (Appeals). Section 193 lists the orders appealable to the Collector (Appeals), and section 25D is not among them. Section 194A(1)(d) sends a section 25D revision order to the Tribunal.

What to check in the official text

Read section 25A in full, including sub-sections (2A) and (4), then section 25D and section 194A(1)(d), (2), (3) and (5). In the site file for the 30 June 2025 edition, section 25A is followed by an earlier version of the same section, printed as sub-sections (1) to (3) again. Check the official PDF to confirm which wording is current. The text of any individual valuation ruling is issued separately and is not held in this corpus.