Customs valuation remanded for fresh determination under the applicable Section 14 regime for each consignment.

The valuation dispute required reassessment under the correct statutory regime for each consignment because the imported goods related to different periods and the applicable Section 14 valuation rules had to be identified separately. The earlier valuation order had proceeded under the Customs Valuation Rules, 2007, while the appellant maintained that the pre-2007 regime governed the main import. As the parties accepted that the issue needed reconsideration by the appellate authority, the Tribunal made no findings on the merits and left all substantive questions open. The matter was remanded to the Commissioner (Appeals) for fresh determination of assessable value after hearing the appellant.

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Issues: Whether the impugned valuation order should be set aside and the matter remanded for re-determination of assessable value under the applicable Section 14 and valuation rules for each consignment.

Analysis: The imported goods covered different periods, and the valuation dispute could not be decided without applying the correct statutory regime to each consignment. The earlier order had proceeded on the basis of the Customs Valuation Rules, 2007, whereas the appellant contended that the pre-2007 regime applied to the main import. The parties agreed that the valuation exercise required reconsideration by the appellate authority in the light of the applicable provisions for the relevant period. The Tribunal therefore refrained from recording findings on the merits and left all substantive questions open.

Conclusion: The matter was remanded to the Commissioner (Appeals) for fresh determination of value under the applicable Section 14 and valuation rules after giving the appellant an opportunity of hearing.

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