Customs valuation requires valid reasons and comparable imports before rejecting transaction value and enhancing assessable value.

Transaction value under customs valuation law must be accepted as the starting point unless the proper officer records valid reasons to doubt its truth or accuracy and supports any substitute valuation with lawful comparability to identical or similar goods. Enhancement based mainly on NIDB data was unsustainable because the record did not establish proper grounds for rejecting the declared value, nor did it show that the relied-upon imports were truly comparable after considering commercial level, quantity and other relevant factors. The enhancement of the assessable value was therefore set aside and relief was granted to the assessee for the disputed bills of entry.

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Issues: Whether the enhancement of the assessable value by rejecting the declared transaction value and relying on NIDB data and contemporaneous imports was lawful.

Analysis: Under Rule 4 of the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988, the transaction value is the starting point for valuation and must be accepted unless the conditions for rejection are satisfied. Rejection of the declared value requires recorded reasons to doubt its truth or accuracy, and the substitute valuation must be supported by proper comparison with identical or similar goods, taking account of commercial level, quantity and other relevant parameters. The record did not show any proper basis for doubting the declared value, and the enhancement rested mainly on NIDB data without establishing that the relied-upon imports were truly comparable. NIDB data can only serve as a guideline and cannot be directly applied without satisfying the statutory requirements for comparable goods.

Conclusion: The rejection of the transaction value and the consequent enhancement of value were not sustainable, and relief was granted to the assessee by setting aside the enhancement for the disputed bills of entry.

Final Conclusion: The customs valuation adopted by the lower authority could not be sustained in law for want of proper reasons and valid comparative material, so the assessee succeeded in the appeal.

Ratio Decidendi: Transaction value under customs valuation law cannot be rejected or enhanced merely on the basis of NIDB data unless the proper officer records valid reasons to doubt the declared value and establishes lawful comparability with identical or similar goods.

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