Transaction value for imports cannot be rejected solely on higher contemporaneous prices without exceptional circumstances under valuation rules.

Declared transaction value for imported goods cannot be rejected merely because contemporaneous imports of similar goods from the same country were assessed at higher prices. Rejection is permissible only where the exceptional circumstances recognised under the valuation rules are established. Here, the sole basis for discarding the declared value was a comparison with higher-priced contemporaneous imports, which was not legally sufficient to displace the transaction value. The declared value was therefore required to be accepted, and the rejection of value and consequential loading were set aside in favour of the importer.

---

---

Issues: Whether the declared transaction value of imported goods could be rejected merely because contemporaneous imports of similar goods from the same country were made at higher prices.

Analysis: Rejection of transaction value is permissible only when the exceptional circumstances contemplated by the valuation rules are shown to exist. A higher contemporaneous import price, by itself, does not justify discarding the declared value. On the facts, the sole basis for rejection was comparison with other imports at higher prices, which was not a legally sufficient ground to displace the transaction value.

Conclusion: The declared transaction value was required to be accepted, and the rejection of value and consequential loading were set aside in favour of the appellants.

Ratio Decidendi: Transaction value cannot be rejected unless the statutorily recognised exceptional circumstances are established, and contemporaneous higher import prices alone are insufficient to displace the declared value.

---