December 21, 2020

The Secretary,
Ministry of Commerce & Industry.
Government of Pakistan,
ISLAMABAD.

Request for reconsideration of Valuation ruling policy

Dear Sir,

Interwood Mobel Private Limited is leading furniture manufacturer with ISO certification in
Pakistan. We are 100% compliant of all the rules & regulations of the country, we have
contributed towards Government exchanger approximately Rs.300 Million through various taxes
in last one year.  We believe on innovation which is one of our core values. We always search
for new technologies to enhance the quality of our production lines. We are also among those
industrial units which have not laid off any worker during this pandemic crisis and also trying to
fulfill all our financial and social obligations.

The company over the past few decades has duly contributed a major share towards the domestic
products.

Being one of the Innovative furniture manufacturers, we need to import few specialized Fabrics
for manufacturing of our products. It is learnt that Government has revised Valuation Ruling of
Fabric Through Valuation Ruling No 1454/2020 Dated 24th June 2020, without following the
express provisions envisaged u/s 25 of the Customs Act, 1969, in sequential order.

We are importing these specialized fabrics at @US$ 4.75/kg as compared to the price of USD
9.50/kg mentioned in said valuation ruling, which is way much exaggerated then the actual price
paid by us.

In view of the above said facts & figures, for instance in case we accept the Valuation Ruling
1454/2020 dated 24th June 2020 @USD 9.50/ kg being exaggerated / hypothetical, we can’t
compete in the open Market as against the actual Transaction Value declared at the import stage
@USD 4.75/ kg against appropriate & correct HS code 5512.1900 declared and duly accepted by
the Customs Appraisement.

However, despite the fact that Customs accepts / classify the impugned goods under declared HS
code 5512.1900 not mentioned under the said Valuation Ruling, while the irrelevant/ invalid
Valuation Ruling issued for HS Code 5513 & 5514 is illegally applied.
In this context, the Valuation Ruling beyond the 90 days has been challenged vide Review
Petition dated 18th December 2020 before the Director Customs Valuation KARACHI.

However, despite all the hardships, we always strive our best to give benefit to society by
providing them quality products and we need your support to continue this legacy and want that
customs officials should invite all stake holders before finalizing the Valuation Rulings. So that
actual DATA should be presented for the ease of traders and officials for making decision.

Looking forward to have a positive response from your side on all the requests.

Very truly yours,

Omar Farooq

Chief Executive Officer | Interwood Mobel Pvt. Ltd.

Independent Director |SME Bank
Regional Finance Officer |YPO (Middle East / North Africa)