Transaction value rejection requires reasons, disclosed basis and proper valuation procedure; unsupported enhancement of import value fails.

Declared transaction value for imported goods cannot be rejected and the assessable value cannot be enhanced unless the rejection is supported by recognised grounds, the importer is told the basis for the proposed variation, and the prescribed valuation procedure is followed. Mere reference to a lower declared value, market price, or a general market enquiry is insufficient where no particulars, comparable import data, or other reliable material are disclosed. On the facts noted, the assessment orders gave no legally sustainable basis for loading the value, and the appellate order did not cure that defect. The rejection of transaction value and enhancement of assessable value were therefore unsustainable.

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Issues: Whether the declared transaction value of the imported goods could be rejected and the assessable value enhanced without recording reasons, disclosing the basis of enhancement, or following the prescribed procedure.

Analysis: The imported goods were assessed at higher values, but the orders did not state any legally permissible ground for rejecting the declared transaction value. The valuation rules require transaction value to be accepted unless it is rejected on recognised grounds, and the importer must be informed of the reasons and the proposed alternative basis of valuation. The orders under challenge contained no material showing any proper market enquiry, comparable import data, or other reliable basis for the enhanced values. The appellate order also did not cure the defect, as it merely referred in general terms to a lower declared value and a loading based on market price and market enquiry without particulars.

Conclusion: The rejection of the transaction value and the enhancement of assessable value were unsustainable, and the challenge to the assessment succeeded.

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