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Issues: Whether the assessable value of imported goods could be enhanced by rejecting the declared transaction value without cogent evidence, and whether reliance on NIDB data and a general guideline was sufficient to sustain such enhancement.
Analysis: The declared transaction value can be rejected only on legally sustainable grounds supported by evidence. Enhancement of value must rest on record material, including proper consideration of contemporaneous imports with reference to quality, quantity, country of origin, and time of import. Mere reliance on NIDB data is not sufficient by itself. The general guideline referred to by Revenue did not justify enhancement in the absence of first establishing why the declared value should be rejected. No convincing evidence was produced to show that the declared value was not the true commercial value of the goods.
Conclusion: The rejection of the declared transaction value was not justified, and the enhancement of assessable value was unsustainable. The appeal failed.
Ratio Decidendi: Transaction value under customs valuation can be displaced only on the basis of cogent evidence and legally permissible grounds; NIDB data or administrative guidelines alone cannot justify enhancement without first establishing valid rejection of the declared value.
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