Customs transaction value cannot be rejected without proof of a recognised exception and supporting contemporaneous evidence.

Declared transaction value under the customs valuation scheme can be rejected only if the Department establishes a recognised exception and supports that rejection with cogent evidence. On the facts, the importer's declared value was backed by back-to-back commercial documents, a negotiated bundled price, and assessment of identical goods for the same supplier and customer by another Customs House at Kolkata. The Department failed to show contemporaneous higher-priced imports or any other disqualifying circumstance, and a higher discount by itself was insufficient where quantity discount and package pricing were commercially explained and documented. The declared transaction value was therefore required to be accepted.

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Issues: Whether the declared transaction value of the imported goods could be rejected and substituted by the Department in the absence of evidence showing contemporaneous higher-priced imports or any exception to acceptance of transaction value.

Analysis: The declared value was supported by back-to-back commercial documents, a negotiated bundled price, and assessment of identical goods at the same supplier and for the same customer by another Customs House at Kolkata. The Department did not establish any circumstance justifying rejection of the transaction value under the valuation rules, nor did it discharge the burden of showing that the declared price was not the true transaction value. The higher discount by itself was held to be insufficient for rejecting valuation when quantity discount and package pricing were commercially explained and supported by documents.

Conclusion: The declared transaction value was required to be accepted and the Revenue's challenge failed.

Ratio Decidendi: Transaction value under the customs valuation scheme can be rejected only when the Department proves the existence of a recognized exception and supports rejection with cogent evidence of contemporaneous higher imports or other legally relevant disqualifying circumstances.

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