Customs valuation cannot rest on market price ranges alone where no contemporaneous import transactions are shown.

PLATT price reports, being compilations of price ranges rather than records of actual transactions, could not by themselves be treated as alternate transaction values for customs valuation. In the absence of evidence of contemporaneous imports, the declared value could not be enhanced on the basis of those reports. The commentary also states that the Commissioner (Appeals) was correct in setting aside the order-in-original, and that the appellate valuation was legal and proper.

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Issues: Whether PLATT price reports could be used to enhance the value of imported goods in the absence of contemporaneous imports and whether the Commissioner (Appeals) was right in setting aside the order-in-original.

Analysis: PLATT price reports were found to be compilations of price ranges and not records of actual transactions. Such reports, being region-wise and not country-specific, were held not to represent alternate transaction values for the purpose of valuation. In the absence of details of contemporaneous imports, the declared value could not be displaced on the basis of PLATT prices. The appellate order was therefore found to be legal and proper and free from infirmity.

Conclusion: The use of PLATT prices for valuation was not accepted, and the Revenue's challenge to the Commissioner (Appeals)' order failed.

Final Conclusion: The valuation adopted by the lower appellate authority was sustained, and the Revenue's appeal was rejected.

Ratio Decidendi: Price ranges compiled in market reports, without evidence of actual contemporaneous transactions, cannot by themselves constitute transaction value for customs valuation.

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