Customs valuation requires rejection of declared transaction value first; unreliable NIDB data cannot justify enhancement.

Customs valuation cannot be enhanced unless the declared transaction value is first rejected on cogent evidence. In the absence of such rejection, an upward revision under Section 14 of the Customs Act, 1962 is not sustainable. Reliance on NIDB data alone was held insufficient because that data was treated as unreliable for fixing a higher import value. The enhancement was therefore set aside, and consequential relief followed.

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Issues: Whether the enhancement of the declared value of imported goods was sustainable in the absence of rejection of the transaction value, and whether reliance on NIDB data could justify such enhancement.

Analysis: Enhancement of customs value requires the Revenue first to reject the declared transaction value on the basis of evidence to the contrary. In the absence of such rejection, value cannot be enhanced under Section 14 of the Customs Act, 1962. The reliance placed on NIDB data was found insufficient, as such data was treated as unreliable for determining higher value of imported goods.

Conclusion: The enhancement of value was unsustainable and was set aside.

Final Conclusion: The appeals succeeded and the appellant was granted consequential relief.

Ratio Decidendi: Customs valuation cannot be enhanced unless the declared transaction value is first rejected on cogent evidence, and unreliable data alone cannot justify an upward revision.

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