Transaction value under customs valuation cannot be rejected without statutory grounds; non-comparable imports are insufficient.

Imported goods' declared transaction value could not be rejected because the Revenue relied on comparable imports of different country of origin and different quantity, which were not truly comparable under the Customs Valuation Rules. In the absence of any allegation of extra consideration, flow-back, or other statutory ground showing that the declared price was affected, the transaction value remained acceptable. The mere presence of a higher invoice value for non-comparable imports did not justify discarding the importer's declared value, and the valuation challenge failed.

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Issues: Whether the declared transaction value of imported goods could be rejected on the basis of comparable imports of different country of origin and different quantity, in the absence of any allegation of extra consideration or other circumstances under Rule 4(2) of the Customs Valuation Rules, 1988.

Analysis: The imported goods were of Taiwanese origin, while the imports relied upon by the Revenue were of Thai origin and also involved a different quantity. The mere existence of a higher invoice value for goods of a different origin and not truly comparable did not justify rejection of the transaction value. In the absence of any allegation that the price declared by the importer was affected by flow-back or any additional consideration, the conditions for discarding the transaction value were not satisfied.

Conclusion: The declared transaction value could not be rejected and the Revenue's appeal failed.

Ratio Decidendi: Transaction value cannot be discarded unless the statutory grounds for rejection are shown to exist, and imports of different origin or non-comparable quantity are not sufficient comparables for valuation.

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