Customs valuation must be tied to relevant import material, and unsupported revaluation may be remitted for fresh consideration.

Customs valuation for duty and redemption fine must rest on material linked to the relevant transaction and the time of import. Here, the revaluation was based on third-party quotations, but the record did not show that those quotations related to the goods or the relevant import date. The existing finding on revaluation was therefore not treated as conclusive, while the remaining findings were left undisturbed. The valuation issue was remitted to the Tribunal for fresh consideration and disposal on the basis of material to be placed by the parties.

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Issues: Whether the revaluation adopted for computation of duty and redemption fine was supported by material relating to the relevant time of import, and whether that question required reconsideration by the Tribunal.

Analysis: The only surviving controversy was the correctness of the revaluation basis. The valuation was founded on quotations said to have been obtained from a third party, but the record did not establish that those quotations related to the transaction in question or to the time of import. In these circumstances, the existing finding on revaluation could not be treated as conclusive, while the other findings were left undisturbed.

Conclusion: The question of revaluation for computation of duty and redemption fine was sent back to the Tribunal for fresh consideration and disposal on the basis of material to be placed by the parties.

Final Conclusion: The decision sustained the remaining findings but reopened the valuation question for fresh adjudication, resulting in a remand on that limited issue.

Ratio Decidendi: Where valuation for customs duty and redemption fine depends on quotations or comparable material, the basis must be shown to relate to the relevant transaction and relevant time; failing such correlation, the issue may be remitted for reconsideration.

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