Customs valuation of black raisins rejected where comparable goods and market data were not reliably matched.

Declared import value of black raisins without seeds could not be enhanced under Rule 7 of the Customs Valuation Rules, 1988 because the goods imported were of different quality from the goods used for loading and the department did not reliably show that its market price data related to the same product. The importers supported the declared value with certificates from trade associations, and the record did not establish common conditions and quality factors between the compared goods. The loading was therefore not justified, and the order setting aside the enhancement was upheld.

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Issues: Whether the enhancement of the declared import value of black raisins without seeds was justified under Rule 7 of the Customs Valuation Rules, 1988.

Analysis: The imported goods were of a different quality from the goods used as the basis for loading, and there was no reliable showing that the market price relied upon by the department related to black raisins without seeds. The importers supported their declared value with certificates from trade associations, and the material on record did not establish that the conditions and quality factors were common to both sets of goods so as to justify enhancement.

Conclusion: The enhancement of value was not justified and the order of the Commissioner (Appeals) setting aside the loading was upheld.

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