Declared transaction value cannot be rejected on NIDB data alone without independent evidence of comparable imports and undervaluation.

Declared transaction value of imported goods cannot be enhanced on the basis of NIDB data alone unless the Revenue first produces independent and cogent evidence that the invoice value is incorrect. Comparable imports must be shown to match in material respects, including type, quality and characteristics; goods in the same broad category are not enough. A Chartered Engineer's report based only on visual inspection, without cross-examination or supporting material, is not decisive. In the absence of evidence of additional consideration or other independent proof, rejection of the declared value and the resulting duty demand and penalties are not sustainable.

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Issues: Whether the assessable value of the imported electric motors could be enhanced on the basis of NIDB data and a Chartered Engineer's report without first rejecting the declared transaction value on the strength of cogent evidence.

Analysis: The declared invoice value can be displaced only after the Revenue produces tangible material showing that the transaction value is incorrect. Mere reliance on NIDB data is insufficient unless the alleged contemporaneous imports are shown to be comparable in all material respects, including type, quality and characteristics of the goods. Electric motors of different winding material and durability cannot be treated as identical merely because they fall in the same broad category. The Chartered Engineer's opinion, based only on visual inspection and not tested by cross-examination, was not treated as determinative. In the absence of evidence of any additional flow-back of money or other independent material, rejection of the declared value was not justified.

Conclusion: The enhancement of value and the consequent duty demand and penalties were not sustainable; the declared transaction value had to be accepted.

Final Conclusion: The appeal succeeded, and the impugned valuation enhancement and connected consequential demands were set aside.

Ratio Decidendi: Declared transaction value of imported goods cannot be rejected and replaced by NIDB data unless the Revenue first establishes, by independent and cogent evidence, that the declared value is incorrect and that the relied-upon imports are truly comparable.

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