Valuation of goods for Customs duty should be done only at the time and place of importation and it should not be based on the bill of lading but on goods arriving in India. The Supreme Court rejected the argument of the Commissioner of Customs that the quantity mentioned in the bill of lading should be the basis of payment of duty, not the quantity actually received in this country.The Customs appellate tribunal had upheld the view of the Customs authorities, but the Supreme Court said that the tribunal had "lost sight of the first principles".