Declared transaction value cannot be rejected using a benchmark price for dissimilar goods without a reliable valuation basis.

Declared transaction value for imported Regrind ABS 20% Glass filled could not be rejected by comparing it with the PLATT price of prime quality ABS. The two goods were materially different, so the benchmark was too remote and unreliable to dislodge the declared value on valuation grounds. A dissimilar market price cannot sustain enhancement unless it provides a reasonable and reliable basis for comparison. On that reasoning, the valuation enhancement was unsustainable and the impugned valuation order was set aside.

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Issues: Whether the declared value of imported Regrind ABS 20% Glass filled could be rejected by comparing it with the PLATT price of prime quality ABS and, on that basis, whether the assessable value fixed by the lower authority could be sustained.

Analysis: The rejection of the declared value was founded on a comparison between commodities that were materially different. The imported product was Regrind ABS 20% Glass filled, whereas the PLATT price relied upon was of prime quality ABS. Such a comparison did not provide a reliable basis to dislodge the transaction value. The connection between the imported goods and the PLATT price was too remote to justify rejection of the declared value on valuation grounds.

Conclusion: The declared value could not be rejected on the basis adopted by the lower authorities, and the valuation enhancement was unsustainable.

Final Conclusion: The appeal succeeded and the impugned valuation order was set aside.

Ratio Decidendi: A declared transaction value cannot be rejected on the strength of an unrelated benchmark price for dissimilar goods unless the comparison is shown to be a reliable and reasonable basis for valuation.

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