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Issues: Whether the assessable value of the imported goods could be enhanced on the basis of a DRI alert and the assessed value in another bill of entry without first rejecting the declared transaction value in accordance with the Customs valuation framework.
Analysis: The declared transaction value cannot be discarded merely because of a DRI alert or because another bill of entry reflects an enhanced assessed value. Enhancement of value must follow the statutory valuation rules and requires rejection of the declared value on legally sustainable grounds. A value already enhanced by the Department cannot itself be treated as the contemporaneous value of similar imports. In the absence of supporting evidence showing that the declared price was not the real transaction value, reliance on assessed bills of entry was not justified.
Conclusion: The enhancement of value was not sustainable. The imported goods had to be assessed on the declared transaction value, and the appeals succeeded.
Ratio Decidendi: Declared transaction value under the Customs valuation scheme cannot be enhanced on the basis of a DRI alert or another assessed bill of entry unless the declared value is first lawfully rejected and supported by evidence showing that it is not the real transaction value.