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Issues: Whether the declared value of imported goods was required to be accepted as the transaction value under Rule 4 of the Customs (Valuation) Rules in the absence of special circumstances justifying rejection, and whether differing values adopted for similar imports from other sources could by themselves justify interference with that valuation.
Analysis: The appeal did not assail the core basis of the appellate order. The governing principle under Rule 4 is that the declared price is to be accepted as the transaction value unless circumstances exist which attract rejection under the rule. The mere fact that similar goods imported from other persons or from the same country had been valued differently was not treated as sufficient to displace the declared transaction value. The appellate authority had proceeded on the binding effect of the rule and on the absence of the conditions necessary to reject the declared value.
Conclusion: The declared value was correctly accepted as the transaction value, and no ground for interference was made out.