Customs valuation requires reliable evidence; an enhanced assessable value cannot rest on an unreliable quotation or ignored import data.

Customs valuation cannot be enhanced on the basis of an unreliable departmental quotation alone; the department must support rejection of the declared value with cogent evidence. The adjudicating authority's enhancement was unsustainable because the quotation relied on had already been discredited, leaving no reliable basis for a higher assessable value. The authority also failed to deal with the importer's contemporaneous import evidence, which was relevant to valuation. The operative principle is that declared value may be rejected only on proper evidentiary support, and all relevant contemporaneous import material must be considered before enhancement is sustained.

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Issues: Whether the assessable value of the imported goods could be enhanced on the basis of the departmental quotation, and whether the order sustained in the absence of consideration of the importer's contemporaneous import evidence.

Analysis: The Tribunal found that the adjudicating authority had fixed the value of the goods mainly on the basis of a quotation said to be for similar goods, but that quotation had already been found unreliable in the connected High Court proceedings. Once that quotation was excluded, no other cogent evidence remained to support the enhanced valuation. The Tribunal also noted that the importer had produced extensive evidence of contemporaneous imports, yet the adjudicating authority had not dealt with that material at all. In valuation matters, the department must adduce reliable evidence to justify rejection of the declared value and enhancement of assessable value.

Conclusion: The enhancement of value was unsustainable and the importer succeeded on the valuation issue.

Final Conclusion: The impugned order could not be sustained because the Revenue failed to justify the enhanced assessable value with reliable evidence and the importer's evidence was ignored.

Ratio Decidendi: In customs valuation, an enhanced assessable value cannot rest on an unreliable quotation alone; the department must support rejection of the declared value with cogent evidence and must consider the importer's contemporaneous import material.

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