Declared transaction value cannot be rejected without comparable contemporaneous imports matching origin and grade.

Declared transaction value of imported goods cannot be rejected or enhanced on the basis of contemporaneous imports unless the relied-upon imports are shown to be comparable in identity or similarity, including country of origin and grade. Where the comparison fails to establish such matching characteristics, NIDB data and similar imports do not provide a sustainable basis for redetermination. On the material noted, the enhancement of value was unsupported, and the declared value was required to be accepted in favour of the assessee.

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Issues: Whether the declared transaction value of the imported goods could be rejected and enhanced on the basis of contemporaneous imports when the relied-upon imports did not match the impugned goods in respect of country of origin and grade.

Analysis: The valuation was redetermined on the basis of contemporaneous imports and NIDB data. The comparison, however, did not establish identity or similarity of the goods, since the relied-upon imports were not shown to be comparable in respect of country of origin and grade. In the absence of matching contemporaneous imports, the basis adopted for enhancement of value could not be sustained, and the declared value could not be displaced on the material placed on record.

Conclusion: The rejection of the transaction value was not justified, and the declared value was liable to be accepted in favour of the assessee.

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