Customs valuation on PLATT prices requires prior rejection of transaction value and adherence to prescribed valuation rules.

Imported goods cannot be revalued on PLATT prices alone unless the transaction value is first rejected by a reasoned speaking order and the Customs Valuation Rules are applied in the prescribed sequence. The authorities must show a legally sustainable basis, such as contemporaneous imports of identical goods or other valid reasons, before enhancing declared value. Reliance on PLATT data without this foundation was inconsistent with natural justice and valuation law, so the enhancement was held unjustified and the impugned orders were set aside in favour of the assessee.

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Issues: Whether the loading and enhancement of the declared value of imported goods on the basis of PLATT's prices, without rejecting the transaction value by a speaking order and without following the prescribed valuation method, was justified.

Analysis: The loading of value was made without recording reasons for rejection of the transaction value and without adherence to the sequence contemplated under the Customs Valuation Rules. The authorities relied on PLATT's prices without first establishing contemporaneous imports of identical goods or otherwise showing why the declared transaction value could not be accepted. Such assessment was also held to be inconsistent with the requirement of a speaking order and contrary to the principles of natural justice. The cited authority on PLATT-based valuation did not assist the Revenue on the facts, because that case involved misdeclaration and a valid basis for rejection of transaction value.

Conclusion: The enhancement of value was unjustified and the impugned orders were liable to be set aside in favour of the assessee.

Ratio Decidendi: Transaction value cannot be rejected, and imported goods cannot be revalued on PLATT's prices alone, unless the authorities first apply the prescribed valuation rules and show a valid basis such as contemporaneous import evidence or other legally sustainable reasons.

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