Transaction value for imports cannot be rejected solely because another importer paid a higher contemporaneous price.

Declared transaction value for imported Ethylene-Di-Chloride cannot be rejected merely because another importer cleared identical goods at a higher contemporaneous price. Without material showing that the declared value was unreliable, differences in price may reflect commercial factors such as quantity, timing, or market movement. The valuation enhancement based only on the other importer's price was therefore unjustified, and the demand founded on that enhancement could not be sustained in favour of the assessee.

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Issues: Whether the transaction value declared for imported Ethylene-Di-Chloride could be rejected merely because another importer had imported the same goods at a higher contemporaneous price.

Analysis: The valuation was enhanced only on the basis of a higher price shown by another importer. The record disclosed no material undermining the declared transaction value. Contemporaneous prices may differ for commercial reasons such as quantity, timing of order, and market fluctuations, and the higher value of another import by itself is not a sufficient basis to discard the assessee's declared price.

Conclusion: The rejection of the transaction value was unjustified and the demand based on the enhanced value could not be sustained, in favour of the assessee.

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