Transaction value rejection fails when customs evidence is unreliable and comparable imports are not properly proved.

Enhancement of the assessable value of imported PU belts was held unsustainable where the Department relied on a circular, NIDB data, contemporaneous imports and market survey material without proving a reliable basis to reject the declared transaction value. The imports were found to be identical, sourced from the same supplier, and declared at materially similar prices in connected matters. The material relied on did not establish that comparable goods were of the same quality, quantity and origin, and the alleged market enquiry was not properly proved. As the evidentiary burden under the Customs valuation framework was not met, the differential duty demand failed.

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Issues: Whether enhancement of the assessable value of imported PU belts and the resulting differential duty demand, based on a DGOV circular, NIDB data, contemporaneous imports and market survey material, was sustainable.

Analysis: The imports in all connected matters were found to be identical, sourced from the same supplier, and assessed on materially similar declared prices. The enhancement was not supported by reliable evidence of contemporaneous imports of like goods at a higher price, nor by a proper and proved market enquiry. Mere reliance on a departmental circular or on unverified NIDB data was held insufficient to displace the declared transaction value. The Department had not established that the imported goods compared were of the same quality, quantity and origin, and the material relied upon did not satisfy the evidentiary burden required to reject the declared value under the Customs valuation framework.

Conclusion: The enhancement of value and the consequential differential duty demand were not sustainable, and the appeals succeeded.

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