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Issues: Whether the declared transaction value of the second hand used diesel engine could be accepted without proper consideration of the valuation report and comparable import evidence, and whether the matter required remand for fresh adjudication.
Analysis: The valuation report and the condition of the imported goods were material pieces of evidence bearing on the correctness of valuation. The lower authorities had not recorded a reasoned finding on the acceptability of that report or adequately weighed the available evidence, though similar goods and comparative imports were relied upon. In such circumstances, the matter could not be finally decided on the existing record and required reconsideration by the adjudicating authority.
Conclusion: The impugned order was set aside and the matter was remanded for de novo adjudication.