Customs valuation by comparable import requires proven identity in goods before enhancing declared value.

Customs valuation requires the Revenue to establish genuine comparability before using a contemporaneous import to enhance declared value. Where the imported goods were described as prepainted coils/sheets on a galvanized base, but the relied-upon benchmark consisted of galvannealed steel sheets in coil with different description and dimensions, and no expert or other material showed identity in quality, size, specifications, or commercial comparability, enhancement of value was not justified. The declared value could not be rejected on the basis of an unproven comparison.

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Issues: Whether the enhancement of the declared value of imported goods was justified on the basis of a contemporaneous import of allegedly comparable goods.

Analysis: The imported goods were described as "Prepainted Coils/Sheets (galvanized base)", while the relied-upon comparison import related to "Galvannealed Steel Sheets in Coil" with different description and dimensions. No expert evidence or other material was produced to establish that the two consignments were identical or comparable in quality, description, size, and specifications. In customs valuation, the Revenue must establish comparability before adopting another import as a benchmark for enhancement of value.

Conclusion: The enhancement of value was not justified and the assessee succeeded on this issue.

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