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Issues: Whether the enhancement of the declared import value without contemporaneous import evidence, without issuing a show-cause notice, and without granting an opportunity of hearing was valid.
Analysis: The declared transaction value was enhanced without any evidence of comparable contemporaneous imports. The burden to justify rejection of the declared value lay on the lower authority. The absence of a show-cause notice and personal hearing amounted to breach of natural justice. The rejection of the transaction value was also found to be contrary to the prescribed procedure under Rule 10A of the Customs Valuation Rules, 1988.
Conclusion: The enhancement of value was invalid and the order of the first appellate authority was upheld.
Ratio Decidendi: Declared import value cannot be rejected and enhanced without evidence of undervaluation, adherence to the prescribed valuation procedure, and observance of natural justice.