Import valuation requires comparable goods evidence; selective data and unexplained price enhancement cannot replace the valuation rules.

Declared transaction value of imported goods could not be rejected merely on selected NIDB entries without examining whether the referenced goods were truly comparable in description, specifications, features, and transaction level, and without placing the full data before the importer. The use of a mid-range price and reliance on capacity alone lacked legal justification, so the enhancement of value was not sustained. The claim for exemption from countervailing duty also required fresh consideration in light of the cited precedents. The impugned order was set aside and the matter remanded for re-assessment under the Valuation Rules and reconsideration of the exemption claim.

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Issues: Whether the declared value of the imported goods could be rejected and enhanced on the basis of selected import data without examining comparability of the goods and the reliability of the data; and whether the claim for exemption from countervailing duty required fresh consideration.

Analysis: The declared transaction value was enhanced only by relying on selected NIDB entries showing higher prices, without placing the full comparable data before the importer or examining whether the referenced goods were truly comparable in terms of description, specifications, features, and transaction level. The capacity of the power bank was not the sole determinant of value, and the method adopted by the Original Authority, including fixation at the middle of the range of prices, was found to lack legal justification. The claim for exemption from countervailing duty also required a clear finding in the light of the cited Supreme Court and High Court decisions.

Conclusion: The enhancement of value was not sustained, and the matter was remanded for fresh re-assessment in accordance with the Valuation Rules while considering the exemption claim afresh.

Final Conclusion: The impugned order was set aside and the dispute was returned for reconsideration on valuation and countervailing duty exemption, with directions to apply the valuation framework strictly.

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