Declared import value cannot be enhanced without reliable contemporaneous comparable evidence for the same goods.

Declared import value for bearings could not be rejected and enhanced merely because the invoices were from traders and the goods were of Japanese and Russian origin. The enhancement lacked support from contemporaneous import data, comparable prices of the same goods, or NIDB evidence, and was based only on an NTN price list with a discount. In the absence of reliable comparable evidence on record, the enhanced assessable value was unsustainable. The impugned order was set aside and consequential relief followed.

---

---

Issues: Whether the rejection of the declared transaction value and enhancement of assessable value of imported bearings was sustainable.

Analysis: The declared value was rejected on the basis that the invoices were from traders and the goods were of Japanese and Russian origin, but the enhancement was not supported by contemporaneous import data or comparable prices of the same goods. The value was loaded only on the basis of an NTN price list with a discount, without bringing reliable comparable evidence on record. In the absence of NIDB data or contemporaneous imports for the impugned goods, the enhancement could not be sustained.

Conclusion: The rejection of the declared value was not justified to the extent that the enhanced value had no proper evidentiary basis, and the enhancement was unsustainable.

Final Conclusion: The impugned order was set aside and the appeal succeeded with consequential relief.

Ratio Decidendi: Rejection of declared import value may not sustain enhancement unless the department establishes the value through reliable contemporaneous import or comparable evidence.

---