Customs valuation requires proof of related-person control before declared transaction value can be rejected.

Declared transaction value under customs valuation law cannot be rejected merely on an asserted related-person relationship. The adjudicating authority relied on an alleged control chain through a joint venture, but no material established that the joint venture controlled the importer or that the parties were related within Rule 2(2)(vi) of the Customs Valuation Rules, 1988. Minutes showing pricing discussions between the foreign supplier group and the Indian collaborator were insufficient to prove statutory control. On that basis, rejection of the declared value was held unjustified and was set aside in favour of the importer.

---

---

Issues: Whether the declared transaction value could be rejected on the ground that the importer and exporter were related persons within Rule 2(2)(vi) of the Customs Valuation Rules, 1988.

Analysis: The adjudicating authority's conclusion rested on the premise that the Indian importer was controlled by a joint venture entity, which in turn was controlled by the foreign supplier. No material was shown to establish that the joint venture controlled the importer. The minutes relied upon only reflected pricing discussions between the foreign supplier group and the Indian collaborator in relation to goods to be exported to India. That document did not support a finding that the importer was under the control of the joint venture or that the parties were related within the meaning of the rule.

Conclusion: The rejection of the declared transaction value was unjustified and was set aside in favour of the appellant.

Ratio Decidendi: A declared transaction value cannot be rejected on the basis of related-person status unless the statutory relationship, including control through a third person, is established by material evidence.

---