Appeal succeeds; declared transaction value upheld as proxy benchmarking under Rule 12 lacked demonstrable similarity and legal basis

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....CESTAT allowed the appeal and set aside the impugned order that had revised assessable value by rejecting the declared transaction value under rule 12 of the Customs Valuation Rules. The Tribunal held that benchmarking against contemporaneous imports required demonstrable similarity and congruity, which the adjudicating authority failed to establish; reliance on an unrelated notation in the First Schedule to compute value was not legally permissible. The assessment based on such proxy methodology was quashed, the challenged revision of assessable value was vacated, and the importers' declared transaction value was consequently upheld.....