Declared transaction value must be accepted absent special circumstances; a later higher contract price alone cannot justify reassessment.

Declared transaction value for imported goods must be accepted where two separate contracts fixed different prices and no extra consideration was shown to have been paid. In the absence of any special circumstance recognised under Rule 4(2) of the Customs Valuation Rules, 1988, the department could not reject the declared value merely because a later consignment was priced slightly higher. A difference of USD 10 per metric ton, by itself, was insufficient to justify substitution of the earlier contract price, and Section 14 of the Customs Act did not support adoption of a higher presumed value on those facts.

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Issues: Whether the declared transaction value for the imported goods could be rejected and the higher price of a later consignment adopted for assessment in the absence of any special circumstance under the valuation rules.

Analysis: The imported goods were covered by two separate contracts entered into at different points of time, with declared prices of USD 840 PMT and USD 850 PMT respectively. No extra consideration over and above the declared prices was shown to have been paid to the supplier. In the absence of circumstances recognised under Rule 4(2) of the Customs Valuation Rules, 1988, the declared transaction value had to be accepted. The mere difference of 10 dollars between the two contract prices, by itself, was insufficient to justify rejection of the earlier declared value. Section 14 of the Customs Act did not support adoption of a higher presumed value on the facts found.

Conclusion: The declared value could not be rejected, and the assessment based on the higher price was unsustainable.

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