Unjust enrichment is irrelevant to assessable value disputes and applies only at the refund stage.

Unjust enrichment cannot be used to justify loading the assessable value of imported goods where the dispute is confined to acceptance or enhancement of the declared value. The text states that enrichment concerns arise at the stage of refund adjudication, not in determining assessable value. Because refund proceedings were separately pending and the Department had not challenged the valuation order on merits, the objection based on possible refund enrichment could not sustain the value loading. The enrichment argument was therefore treated as irrelevant to the valuation issue, and the appeal was not entertained.

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Issues: Whether the loading of assessable value of imported watch components could be sustained on the ground that any refund arising from acceptance of the declared value would result in unjust enrichment.

Analysis: The dispute on valuation was confined to whether the declared value should be accepted or enhanced. The possibility of unjust enrichment is relevant at the stage of refund adjudication and not while determining the assessable value of the imported goods. Since the refund proceedings were separately pending and the Department had not challenged the valuation order on merits, the enrichment objection could not support the loading of value.

Conclusion: The objection based on unjust enrichment was rejected as irrelevant to the valuation issue, and the appeal was not entertained.

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