Customs transaction value cannot be rejected on NIDB data alone without reasonable doubt and genuinely comparable imports.

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....Transaction value remains the primary customs valuation basis and cannot be rejected solely because the declared price appears low. Rule 12 requires reasonable doubt supported by evidence; NIDB data alone was insufficient where the Department did not establish undervaluation, additional consideration, flow-back, or comparability of alleged contemporaneous imports by quantity, commercial level, manufacturer, branding, quality or specifications. The article notes that invalid value enhancement defeats the consequential differential duty and interest demand. Where confiscation rests entirely on the failed undervaluation allegation and no independent misdeclaration is evidenced, confiscation, redemption fine and penalty are also unsustainable.....