Transaction value under customs law cannot be rejected on NIDB data alone without cogent evidence of undervaluation.

Transaction value remains the primary basis for customs assessment under Section 14 of the Customs Act, 1962 read with the Customs Valuation Rules, 1988, and it cannot be rejected merely because contemporaneous imports reflect a higher price. The Revenue must show cogent material creating a real doubt about the truth or accuracy of the declared value, including reliable comparability of the cited imports in identity, similarity, quantity, and commercial terms. Reliance only on NIDB data, without evidence of extra consideration, abnormal discount, or other concrete reasons to displace the declared price, is insufficient. Accordingly, rejection of the declared transaction value and enhancement of assessable value were not justified.

---

---

Issues: Whether the declared transaction value of the imported goods could be rejected on the basis of NIDB data and contemporaneous imports, and whether enhancement of assessable value was justified.

Analysis: Under Section 14 of the Customs Act, 1962 read with the Customs Valuation Rules, 1988, the transaction value is the primary basis for assessment unless the conditions for acceptance are not satisfied or the proper officer has material reasons to doubt its truth or accuracy. Mere difference between the declared price and the prices reflected in contemporaneous imports is not enough; the Revenue must place cogent evidence showing why the declared value is unacceptable. In the present case, the department relied only on NIDB data without establishing that the cited imports were truly comparable in terms of identity, similarity, quantity, or commercial terms. There was no material to show extra consideration, abnormal discount, or any other concrete reason to reject the declared value under Rule 10A.

Conclusion: The declared transaction value could not be rejected and the enhancement of assessable value was not justified. The Revenue's appeals failed.

Ratio Decidendi: Transaction value cannot be rejected merely because contemporaneous imports appear to be at a higher price; rejection requires cogent material showing non-fulfilment of the statutory conditions or a real basis to doubt the declared value.

---