Transaction value of imports cannot be rejected on price comparison alone where contract price and no undervaluation evidence support it.

Declared transaction value of imported goods cannot be rejected merely because identical goods imported contemporaneously in the same vessel were invoiced at a higher price. Where the import is supported by the contract price and there is no evidence of extra consideration, collusion, misdeclaration or undervaluation, contemporaneous price comparison alone does not justify enhancement of assessable value. Different contracts and fluctuating international prices weaken reliance on the higher import price as a benchmark. The declared value was therefore accepted and enhancement of assessable value was not justified.

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Issues: Whether the declared transaction value of imported goods could be rejected and the assessable value enhanced merely because identical goods imported in the same vessel under proximate invoices were available at a higher price, despite the existence of different contracts and fluctuating international prices.

Analysis: The only substantive controversy was valuation of the imported goods. The declared value was supported by the contract price, and there was no evidence of any extra consideration, collusion, misdeclaration, or undervaluation. The higher price of similar goods imported contemporaneously could not, by itself, displace the contracted price where the imports were under different contracts and the market was fluctuating. The principles governing rejection of transaction value required some legally sustainable basis beyond mere price comparison with contemporaneous imports.

Conclusion: The declared transaction value was rightly accepted and the enhancement of assessable value was not justified. The Revenue's appeal was rejected.

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