Declared import value cannot be rejected without reliable evidence; incomparable goods and raw-material prices cannot justify enhancement.

Declared import value for mixed stock lot goods cannot be rejected merely by comparing them with PVC granules or other non-comparable materials. The Department must prove undervaluation with reliable evidence and follow a legally permissible valuation method under the Customs Valuation Rules; contemporaneous import evidence, comparable clearances, and the importer's past assessments must be meaningfully considered. In the absence of reasoned findings and acceptable expert support, enhancement of value, confiscation, redemption fine, and penalty are not sustainable. The text states that the impugned valuation order and consequential penalties were annulled and release of the goods on payment of duty on the declared value was directed.

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Issues: Whether the declared value of imported stock lot goods could be rejected and enhanced under the Customs Valuation Rules, and whether the consequential confiscation, redemption fine, and penalty were sustainable.

Analysis: The imported goods were accepted as a mixed stock lot, while the Department sought to compare them with PVC granules and other not-comparable material. The record did not show any definite or reliable expert opinion establishing the alleged undervaluation, and the adjudicating authority did not meaningfully deal with the importer's contemporaneous evidence, including comparable clearances and the appellant's own previous assessments. In valuation matters, the declared transaction value cannot be displaced unless the Department discharges the burden of proving undervaluation through legally acceptable material, and a notional comparison with unrelated goods or raw material prices cannot justify resort to a higher valuation basis. The absence of reasoned findings also undermined the imposition of redemption fine and penalty.

Conclusion: The enhancement of value was not sustainable, the rejection of the declared value failed, and the confiscation-related redemption fine and penalty were liable to be set aside in favour of the assessee.

Final Conclusion: The appeal succeeded, the impugned valuation order and consequential penalties were annulled, and release of the goods on payment of duty on the declared value was directed.

Ratio Decidendi: Declared import value cannot be rejected on the basis of incomparable goods or raw-material price indicators unless the Department establishes undervaluation with reliable evidence and follows a legally permissible valuation method.

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