Customs valuation enhancement requires recorded reasons, rule-based valuation, and compliance with appellate directions.

Enhancement of the declared assessable value of imported goods must be supported by recorded reasons, comply with Section 14 of the Customs Act, 1962 and the valuation rules, and follow the prescribed sequence for rejecting transaction value. Mere consent of the importer does not cure an arbitrary enhancement, and reliance on unparticularised NIDB data without adequate explanation is insufficient. Where an earlier appellate direction requires a speaking order, later adjudication must meaningfully address the basis for enhancement and record lawful reasons; failure to do so renders the order unsustainable for non-compliance with appellate directions and want of reasoned adjudication.

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Issues: (i) Whether the enhancement of the declared assessable value of imported goods was supported by valid legal grounds and in conformity with the customs valuation framework; (ii) Whether the subsequent order sustaining the enhancement could stand when it did not comply with the earlier appellate directions requiring a speaking order.

Issue (i): Whether the enhancement of the declared assessable value of imported goods was supported by valid legal grounds and in conformity with the customs valuation framework.

Analysis: Enhancement of value has to accord with Section 14 of the Customs Act, 1962 and the valuation rules. Mere consent of the importer does not validate an otherwise arbitrary enhancement. The order enhancing value was found unsupported by details of the NIDB data relied upon, and no satisfactory reasons were given for rejecting the transaction value or for moving beyond the prescribed valuation sequence under the rules.

Conclusion: The enhancement of the declared value was not legally sustainable and was rightly set aside.

Issue (ii): Whether the subsequent order sustaining the enhancement could stand when it did not comply with the earlier appellate directions requiring a speaking order.

Analysis: The earlier appellate order had specifically directed that a speaking order be issued after recording lawful reasons for enhancement. The subsequent adjudication did not supply the required particulars, did not meaningfully justify rejection of the declared value, and did not comply with the earlier directions. The order therefore suffered from non-compliance with Section 17(5) of the Customs Act, 1962 and from lack of reasoned adjudication.

Conclusion: The subsequent order was unsustainable for failure to follow the earlier appellate directions and for want of a proper speaking order.

Final Conclusion: The Revenue's challenge failed because the valuation enhancement was arbitrary, unsupported by recorded reasons, and passed in disregard of binding appellate directions.

Ratio Decidendi: An enhancement of declared import value must be supported by recorded reasons and strict compliance with the valuation rules and appellate directions; unsupported consent of the importer and unparticularised reference data cannot cure an arbitrary enhancement.

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