Import value enhancement needs cogent evidence; NIDB data alone, without importer acknowledgment, cannot justify revision.

Import value enhancement based solely on NIDB data and an examination report was held unsustainable where the importer had not admitted liability or signed any acknowledgment accepting the revised value, and the record disclosed no other cogent evidence supporting the increase. A valuation order cannot rest on suspicion or surmise; it must be backed by reliable material showing the enhanced value is justified. On that basis, the revenue's challenge to the valuation was dismissed.

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Issues: Whether enhancement of the imported value based on NIDB data, without cogent evidence or acknowledgment by the importer, could be sustained.

Analysis: The enhancement was founded on an examination report and NIDB data, but there was no material showing that the importer had admitted liability or signed any acknowledgment agreeing to the enhanced value. The record also did not disclose any other cogent evidence to justify the enhancement. In the absence of supporting evidence, a valuation order could not rest on suspicion or surmise.

Conclusion: The enhancement of value was not sustainable and the Revenue's appeal was dismissed.

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