Customs valuation based on NIDB data fails where declared value is supported by contemporaneous evidence and untested technical reports.

Customs valuation of semi-finished coaxial cables cannot be enhanced solely on NIDB data where the declared value is supported by contemporaneous VAT return evidence and the adverse technical material has not been tested by cross-examination. The approved valuer's report valued the goods by reference to constituent material weight, but that alone did not justify rejecting the declared value for goods not available in the retail market. The declared value was accepted, and enhancement on the basis of NIDB data was not sustainable.

---

---

Issues: Whether the value declared for the imported semi-finished coaxial cables could be rejected and enhanced on the basis of NIDB data and the approved valuer's report.

Analysis: The imported goods were semi-finished and not available in the retail market. The approved valuer's report assessed value on the basis of constituent material weight, while the respondent supported the declared value by VAT return evidence. The Chartered Engineer's adverse certification was also relied upon, but it was not subjected to cross-examination. The Commissioner (Appeals) accepted the declared value on the basis of NIDB data alone.

Conclusion: The value enhancement based on NIDB data was held not sustainable, and the declared value was accepted.

Ratio Decidendi: Customs valuation cannot be sustained solely on NIDB data when the declared value is supported by contemporaneous material and the adverse technical evidence has not been tested by cross-examination.

---