Assessable value enhancement requires contemporaneous import evidence; unsupported revaluation was set aside and remanded for fresh adjudication.

Assessable value of imported goods cannot be enhanced merely on the basis of an admission about the contents of the containers or on assumption; the revenue must support revaluation with contemporaneous import data, market enquiry, or other reliable evidence of market value. In the absence of such material, the proposed enhancement was not sustained. Although misdeclaration was not in dispute, the consequential issues of confiscation, redemption fine, and penalty required fresh consideration after due hearing. The impugned order was set aside and the matter remanded for fresh adjudication on valuation and the related consequences.

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Issues: Whether the assessable value of the imported goods could be enhanced without evidence of contemporaneous import or market enquiry, and whether the matter required fresh adjudication on confiscation, fine and penalty.

Analysis: The record did not disclose any market enquiry or evidence of contemporaneous imports to support the proposed enhancement of value. Mere admission regarding the contents of the containers did not amount to an admission of value, and could not by itself justify revaluation. The question of misdeclaration was not in dispute, but the consequences of confiscation, fine and penalty also had to be reconsidered after affording due opportunity of hearing.

Conclusion: The enhancement of value was not sustained on the existing material. The impugned order was set aside and the matter was remanded for fresh adjudication on valuation and the consequential issues of confiscation, fine and penalty.

Final Conclusion: The appeal succeeded to the extent that the valuation-based order was annulled and the dispute was sent back for reconsideration by the original authority.

Ratio Decidendi: Assessable value cannot be enhanced merely on admission or assumption; the revenue must establish contemporaneous import or other reliable evidence of market value before revising valuation.

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