Assessable value enhancement requires independent evidence; NIDB data alone cannot displace declared transaction value.

Assessable value of imported goods cannot be enhanced merely on the basis of NIDB data. Where the declared transaction value is sought to be rejected, the Revenue must first displace it with reliable contemporaneous import data or other independent evidence showing under-valuation. In the absence of such supporting material, NIDB data alone is insufficient to justify enhancement under the valuation framework. The declared value was therefore upheld and the Revenue's challenge failed.

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Issues: Whether the Revenue was justified in seeking enhancement of the assessable value of the imported goods on the basis of NIDB data in the absence of direct evidence of under-valuation.

Analysis: The impugned order had rejected enhancement because the Revenue failed to produce evidence for rejecting the declared transaction value under the Board's circular framework and also failed to show, by contemporaneous import data or other material, that the declared value was incorrect. The Tribunal agreed that NIDB data by itself is not a sufficient basis for enhancement of assessable value and that, without independent supporting evidence, the declared value could not be disturbed.

Conclusion: The Revenue's appeal was rejected and the assessable value as declared by the importer was upheld.

Ratio Decidendi: Assessable value cannot be enhanced merely on the basis of NIDB data unless the declared transaction value is first displaced by reliable evidence.

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