Declared import value must rest on reliable contemporaneous comparisons, not arbitrary enhancement without proper factual assessment.

Declared import value could not be rejected or enhanced without reliable contemporaneous comparable imports and a proper factual comparison of quantity, timing, and market conditions. The customs authority's reliance on a solitary import, without showing it was comparable or putting proper evidence to the importer, was insufficient to justify ex parte loading of value. Because the valuation rules required a grounded comparison and consideration of the importer's evidence, the enhanced valuation was set aside and the declared value accepted.

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Issues: Whether the loading of the declared import value was justified when no comparable contemporaneous import of similar quantity, time, and market conditions was considered.

Analysis: The declared value could not be discarded on the basis of an ex parte enhancement without proper consideration of the importer's evidence, the bulk quantity contracted and imported, and the prevailing international price trend. The lower authority relied on a solitary import that was not shown to be comparable in quantity or circumstances, and failed to bring any proper contemporaneous import to the importer's notice. In such circumstances, the statutory framework for customs valuation required acceptance of the declared value rather than arbitrary enhancement.

Conclusion: The loading of the declared value was not sustainable and the enhanced valuation was set aside.

Ratio Decidendi: Declared import value cannot be rejected or enhanced unless the revenue establishes reliable contemporaneous comparable imports and applies the valuation rules on a proper factual comparison, including quantity, timing, and market conditions.

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