Customs valuation: declared transaction value prevailed over journal prices and later sale price where contemporaneous imports supported it.

Declared transaction value remained the starting point for customs valuation because the invoice price was supported by the supply arrangement and acceptance letter, and no extra consideration was shown to have passed between buyer and supplier. A later increase in quantity at a concessional price was treated as a normal commercial adjustment, not a basis to reject the declared value. The valuation rules required sequential application only if the prescribed grounds for rejection were established; here, contemporaneous imports in the relevant period showed lower comparable values and were not disproved by the department. Published journal prices and a later high-sea-sale price could not override actual contemporaneous import prices, so the declared value was accepted and Revenue's challenge failed.

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Issues: Whether the assessable value of the imported goods was to be determined on the basis of the declared transaction value and contemporaneous imports, or on the basis of published journal prices and a later high-sea-sale price.

Analysis: The declared invoice price was supported by the supply arrangement and letter of acceptance, and there was no evidence of any additional consideration passing from the buyer to the supplier. The later increase in quantity with a concessional price was treated as a normal commercial adjustment and not as a ground to reject the declared value. Under the valuation scheme, transaction value is the starting point, and rejection of that value requires the existence of the prescribed conditions. If doubt persists, valuation must proceed sequentially through the prescribed rules. The contemporaneous imports referred to by the Commissioner (Appeals) showed lower comparable values in the relevant period, and the department did not disprove those imports. In that situation, the later high-sea-sale price and published journal prices could not displace actual contemporaneous import prices.

Conclusion: The declared transaction value could not be rejected, and the contemporaneous import prices had to prevail over journal prices. The appeal by Revenue failed.

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