Transaction value in customs valuation must be accepted when supported by contemporaneous purchase evidence; confiscation and penalties fall away.

Declared transaction value supported by a contemporaneous purchase invoice from the country of origin must ordinarily be accepted for customs valuation under Rule 4 of the Customs Valuation Rules. The adjudicating objections based on the invoice and transport mode were insufficient to reject that value, and quotation-based or notional alternate methods could not displace a genuine transaction value without valid grounds. On that basis, the rejection of transaction value was unsustainable, and confiscation and penalties were set aside. The additional customs duty liability, however, remained undisturbed.

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Issues: Whether the assessable value of the imported goods was required to be determined on the basis of the declared transaction value, and whether the consequent confiscation and penalties could survive.

Analysis: The declared price was supported by the purchase invoice from the country of origin and the goods were supplied in full to the importer. Under Rule 4 of the Customs Valuation Rules, transaction value is the normal basis for customs valuation unless there is a valid reason to reject it. The objections taken in the adjudication order to the origin invoice and mode of transport were not sufficient to displace the declared value. The internet quotation and other alternate methods could not override a genuine transaction value supported by contemporaneous purchase documents.

Conclusion: The rejection of the transaction value was unsustainable, and the goods were required to be assessed on the declared value. The confiscation and penalties were set aside, while the additional customs duty was maintained.

Final Conclusion: The importer succeeded on the valuation dispute, with consequential relief against confiscation and penalty, but the liability to additional customs duty remained undisturbed.

Ratio Decidendi: Where the declared transaction value is supported by reliable contemporaneous purchase evidence from the country of origin, it must ordinarily be accepted for customs valuation and cannot be displaced by quotation-based or notional alternate methods without valid grounds for rejection.

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