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Issues: Whether the original price of the imported second-hand machines in the year of manufacture should be taken at US $ 88,000 per machine or at US $ 55,000 per machine for valuation purposes.
Analysis: The supplier's communications gave inconsistent figures for the original price of the machines, and the later reduction to US $ 55,000 was not supported by any satisfactory explanation showing why the earlier figure of US $ 88,000 was . The record also did not explain why the first valuation should be discarded or on what basis it was subsequently revised. In the absence of a credible explanation from the importer or the supplier, the later revision of the price was not accepted.
Conclusion: The higher original price of US $ 88,000 per machine was upheld and the importer's contention was rejected.