Transaction value for related-party sales stands when competitive bidding shows price independence and no relationship-based influence.

For clearances to a related buyer, the declared transaction value cannot be rejected under valuation rules merely because of the relationship. Where the sales were fixed through an open tender and competitive bidding process, and the record showed sales of the same product to other buyers at the same or lower prices, the price was treated as the sole consideration. In the absence of evidence that the relationship influenced the price, the higher assessable value could not be adopted. On that basis, the duty demand, interest and penalty based on revaluation could not survive.

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Issues: Whether the transaction value for clearances of poly iso butane to a related buyer could be rejected and a higher assessable value adopted under the valuation rules.

Analysis: The clearances to the buyer were made pursuant to an open tender and competitive bidding process. The record also showed sales of the same product to other buyers at the same or lower prices during the disputed period. In the absence of evidence that the price was influenced by the relationship, and since price remained the sole consideration, there was no justification for discarding the declared transaction value and resorting to valuation under the rules.

Conclusion: The transaction value was required to be accepted, and the duty demand, interest and penalty based on revaluation could not survive.

Final Conclusion: The assessee succeeded on the valuation dispute, and the Revenue's challenge failed as a consequence.

Ratio Decidendi: Where sales to a related buyer are independently fixed through a transparent competitive bidding process and no evidence shows that the relationship influenced price, the declared transaction value cannot be rejected merely because the buyer is related.

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