Separate assessable value under distinct buyer classes upheld where no related-person relationship was shown.

Different assessable values may be accepted under separate price lists for distinct classes of buyers where no related-person relationship is established. The trade practice of classifying buyers supported acceptance of the Part-II price list, and the absence of any extraneous circumstance justified rejection of the Department's challenge to the lower prices declared there. The separate assessable value under Part-II was upheld for the same goods, notwithstanding the existence of a Part-I price list.

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Issues: Whether a separate assessable value could be adopted under Part-II price list when a Part-I price list also existed for the same goods.

Analysis: Different prices may be filed for different classes of buyers where the buyers are not related persons. The absence of any established relationship between the assessee and the buyer, together with the recognition of trade practice in identifying classes of buyers, supported acceptance of the Part-II price list. No extraneous circumstance was shown to justify rejection of the lower prices declared in Part-II.

Conclusion: The Department's objection was not accepted and the separate assessable value under Part-II price list was upheld.

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