Comparable-import valuation requires truly similar goods; undisclosed material and dissimilar imports cannot justify higher assessable value.

Declared invoice value of imported HDPE could not be rejected on the basis of another importer's price or an undisclosed trade report. Comparable-import valuation was inapplicable because the relied-upon import involved a much smaller quantity and a different grade, so it was not a safe benchmark under the valuation rules. Material not disclosed in the show cause notice could not be used to enhance value. The proper course was to assess the appellants' contemporaneous import documents and redetermine assessable value on proper evidence. The Collector's valuation was therefore set aside to that extent and the matter remanded for fresh determination.

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Issues: Whether the assessable value of imported HDPE could be rejected by relying on the price of another importer and an external trade report, and whether the matter required re-determination of value on proper evidence.

Analysis: The declared invoice value was supported by the sale confirmation and related shipment documents, and the goods could not be valued by reference to another import unless the comparative import was of similar goods at the same commercial level and in substantially the same quantity. The relied-upon comparable import was of a much smaller quantity and different grade, so it could not safely serve as the benchmark under the valuation rules. The trade report also could not be used because it had not been put to the appellants in the show cause notice. The proper course was therefore to examine the appellants' own contemporaneous import documents and determine value in accordance with the valuation rules.

Conclusion: The valuation adopted by the Collector was set aside to that extent, and the matter was remanded for fresh determination of assessable value on proper material.

Ratio Decidendi: Comparable-import valuation can be applied only where the alleged similar goods are truly comparable in grade, quantity, and commercial level, and material not disclosed in the notice cannot be relied upon to enhance value.

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