Declared value of imported goods upheld where a higher-price comparison invoice involved materially different quantities.

Declared value of imported goods could not be rejected merely because a relied-upon invoice showed a higher price for similar goods from the same supplier on the same date, where the imported quantity was materially larger. Quantity was a relevant factor affecting the sale consideration, and the comparison invoice was not a reliable basis to discard the declared value on those facts. The Revenue's appeal failed.

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Issues: Whether the declared value of imported goods could be rejected on the basis of an invoice showing a higher price for similar goods imported from the same supplier on the same date, despite substantial difference in quantity.

Analysis: The quantities imported by the respondent were materially higher than the quantity covered by the relied-upon invoice. Quantity was a relevant factor affecting the consideration for sale, and the comparable invoice was not a reliable basis for discarding the declared value where the respondent imported almost double the quantity.

Conclusion: The declared value could not be rejected on the facts presented, and the Revenue's appeal failed.

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