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Issues: Whether the assessable value of the imported worn clothing could be enhanced on the basis of NIDB data and other contemporaneous imports, or whether the declared transaction value was required to be accepted.
Analysis: The declared price of imported goods is to be accepted as the transaction value unless the case falls within the exceptions permitting rejection of that value. In the case of worn and used clothing, comparative reliance on other consignments requires material showing that the imports are truly comparable in quality, type, use and condition. Mere reference to NIDB data or other import entries, without proof that any exception under the valuation rules applies and without evidence of extra payment or special relationship, is insufficient to discard the declared value.
Conclusion: The enhancement of assessable value was not justified and the declared transaction value had to be accepted.
Final Conclusion: The Revenue's challenge to the valuation determination failed, and the order rejecting the enhanced assessable value was sustained.
Ratio Decidendi: Declared transaction value under the customs valuation regime cannot be rejected unless the department proves the applicability of a recognised exception, and contemporaneous imports may be relied upon only when true comparability is established.