Comparable-value valuation requires proof of identical or similar imports; mere reference to another shipment cannot justify enhancement.

Declared value of imported citric acid could not be rejected on the basis of another import unless the comparison import was shown to be identical or similar and the material particulars needed to test comparability were available. For the comparable-value method, details such as origin, quantity and other relevant facts must support the alleged benchmark import; a bare reference to the same commodity or supplier is insufficient. The declared value was therefore accepted and the proposed enhancement failed for lack of a valid comparable import.

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Issues: Whether the declared value of the imported citric acid could be rejected and enhanced on the basis of another import without furnishing adequate details of comparability.

Analysis: For resort to the comparable-value method under the valuation rules, the goods relied upon for comparison must be shown to be identical or similar and the relevant details of the alleged comparable import, including origin, quantity and other material particulars, must be available. A mere reference to another import of the same commodity, or to the same supplier, is insufficient where the material particulars needed to test comparability are absent.

Conclusion: The declared value was rightly accepted and the attempt to enhance value failed for want of sufficient details of a valid comparable import.

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