Transaction value rejection requires a lawful basis; unsupported enhancement of imported goods' assessable value was unsustainable.

Assessable value of imported goods cannot be enhanced unless the rejection of the declared transaction value is supported by a discernible and lawful basis. The record showed that the adjudicating authority relied on general practice and NIDB data without any concrete material, hard copy, or specific foundation to justify the enhancement. Earlier clearance of the goods and payment of duty did not bar the importer from challenging the assessment. On that basis, the enhancement of value was held unsustainable and the declared transaction value was accepted in favour of the assessee.

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Issues: Whether the enhancement of the assessable value of the imported goods was justified and whether the declared transaction value could be rejected without a discernible basis.

Analysis: The record showed that the adjudicating authority had enhanced the value without any ascertainable basis. The clarification called for by the appellate authority did not disclose any concrete material supporting enhancement and merely referred to general practice and NIDB data, without any hard copy or specific foundation being available on record. In these circumstances, the earlier clearance of the goods and payment of duty did not by itself bar the importer from challenging the assessment, and the absence of a proper basis for rejection of the declared value remained decisive.

Conclusion: The enhancement of value was held unsustainable and the transaction value was accepted in favour of the assessee.

Ratio Decidendi: Assessable value cannot be enhanced unless the rejection of the declared transaction value is supported by a discernible and lawful basis.

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