Customs valuation cannot rest on NIDB data alone; transaction value requires Rule 12 process before enhancement.

Declared invoice value remains the starting point for customs valuation under Section 14(1) of the Customs Act, 1962, and it can be displaced only if the proper officer records reasonable doubt about its truth or accuracy and follows Rule 12 of the 2007 Valuation Rules before moving sequentially through Rules 4 to 9. Higher NIDB data alone does not establish undervaluation or justify rejection of transaction value. In the absence of independent inquiry or other material supporting doubt, enhancement of assessable value was not sustainable and the appeal was allowed.

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Issues: Whether the declared transaction value of the imported goods could be discarded and the assessable value enhanced merely on the basis of NIDB data without complying with the valuation procedure under the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007.

Analysis: The declared invoice value is the starting point under Section 14(1) of the Customs Act, 1962. A departure from that value requires the proper officer to have a reasonable doubt about the truth or accuracy of the declared value and to follow the procedure under Rule 12 of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007 before moving sequentially to Rules 4 to 9. Mere reliance on higher values reflected in NIDB data does not by itself establish such reasonable doubt. The record did not show any independent inquiry or material indicating under-valuation, nor was the transaction value rejected in the manner required by the valuation rules.

Conclusion: The enhancement of value was unsustainable and the appeal was allowed.

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