Transaction value in customs valuation cannot be rejected by contemporaneous imports absent the rule-based grounds for disallowance.

Transaction value of imported goods must be accepted under the amended customs valuation regime unless the specific grounds for rejection in Rule 4(2) are established. Where the declared price is supported by a contract, the import falls within the contracted period, and there is no evidence of related-party dealing, extra-commercial consideration, or additional payment, the declared value cannot be displaced by contemporaneous import prices. The residual valuation method cannot be invoked inconsistently before the preceding valuation rules, including the rule for identical goods, have failed. On these facts, the assessable value was properly based on the contracted price, subject only to the importer's voluntary marginal enhancement.

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Issues: Whether the declared transaction value of imported goods could be rejected and the assessable value determined on the basis of contemporaneous imports under the Customs Valuation Rules, 1988.

Analysis: The declared price was supported by a contract and the import was within the contracted period. No evidence showed that any amount over and above the contracted price was paid or payable, that the importer and supplier were related, or that the price was influenced by extra-commercial considerations. The original authority invoked the residual method while also relying on contemporaneous imports, which was inconsistent because Rule 8 could apply only after the preceding rules, including the rule governing identical goods, had failed. The amended valuation rule and Section 14 required acceptance of transaction value unless the special circumstances in Rule 4(2) were established. The contemporaneous price relied on by the department did not displace the transaction value on these facts.

Conclusion: The declared transaction value could not be rejected and the assessable value was rightly based on the contracted price as modified by the importer's voluntary acceptance of a marginal enhancement.

Ratio Decidendi: Under the amended customs valuation regime, transaction value must be accepted unless the specific grounds for rejection are established, and contemporaneous import prices cannot be used to displace it in the absence of those grounds.

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