Natural justice in customs valuation requires disclosure of enhancement basis, a hearing, and a speaking order before revising declared value.

Where customs authorities propose enhancement of the declared import value, the importer must be informed of the basis for enhancement and given a fair opportunity to respond, consistent with natural justice and the customs framework. A speaking order is required unless enhancement is accepted in writing, and the appellate authority may examine the original assessment and remand the matter where necessary. The order setting aside the enhancement and the assessment was therefore set aside, and the matter was remanded to the original authority for a speaking order after giving reasonable hearing.

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Issues: Whether the enhancement of the import value and the appellate order setting aside such enhancement required reconsideration on the basis of a speaking order and a fair opportunity to the importer.

Analysis: The appeal arose from enhancement of the declared value of imported goods on the basis of import data and the Commissioner (Appeals)' setting aside of that enhancement. The order emphasised that where value is proposed to be enhanced, the procedure must conform to natural justice and the Customs law framework. It noted that the basis for enhancement should be made known to the importer and an opportunity afforded before decision, and that the Board's instructions contemplate dispensing with a speaking order only where enhancement is accepted in writing. It further observed that the appellate authority should examine the basis of the original assessment and, where necessary, can remand the matter for a proper speaking order.

Conclusion: The order of the Commissioner (Appeals) and the assessment order were set aside and the matter was remanded to the original authority for a speaking order after giving reasonable opportunity of hearing.

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