(1.) Heard both sides. The appellant filed this appeal against the Order -in -Appeal passed by the Commissioner (Appeals).
(2.) The facts of the case are that the appellant made import of optical heads for CD Player. The value declared by the appellant in respect of the imported goods was not accepted by the Revenue and the same was enhanced on the basis of import made by the other importer of similar goods.
(3.) The contention of the appellant is that the value declared by them is the transaction value at which the goods had been purchased from abroad and the transaction value is required to be accepted for the purpose of assessment of goods. The contention is that the transaction value has been rejected without any reason and the value has been enhanced on the basis of value declared by other importers of heads for YCD whereas the appellant made import of heads for CD Players and these are two different distinct and items.