Declared import value cannot be enhanced on unverified portal data without proof of reliability and comparability of goods.

Declared import value cannot be rejected or enhanced merely on the basis of unverified third-party portal data. The department relied only on Zuaba data, but the platform's authenticity and reliability were not established, and the referenced goods were not shown to be identical or similar because the country of origin and description differed. In the absence of independent evidence creating doubt about the declared value, the burden to justify rejection of that value was not discharged. Reliance on the cited Supreme Court decision was distinguished because related persons were not involved.

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Issues: Whether the declared value of the imported stock lot of jute bags could be rejected and enhanced on the basis of data from the Zuaba portal.

Analysis: The department enhanced the value by relying solely on Zuaba data. The authenticity of that private platform was not established and no effort was made to verify its reliability. The data also did not show that the referenced goods were identical or similar to the goods under import, since the country of origin and the description of the goods were different. In the absence of other evidence creating doubt about the declared value, the burden to justify rejection of the declared value was not discharged. The reliance on the cited Supreme Court decision was distinguished on facts because the feature of related persons was absent.

Conclusion: The rejection of the declared value and the enhancement of assessable value were unsustainable.

Final Conclusion: The assessment based on enhanced value was set aside and the appeal was allowed with consequential relief.

Ratio Decidendi: Declared import value cannot be rejected merely on the basis of unverified third-party data unless the department establishes the reliability of the material and shows that the relied-upon goods are comparable to the goods under import.

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