Transaction value for imported silk cannot be rejected on contemporaneous imports alone without cogent reasons.

Declared transaction value for imported mulberry raw silk cannot be rejected merely because contemporaneous imports reflected a higher price. The declared invoice value was supported by contract documents, and the department failed to show any discrepancy in the contract, any relationship between the parties, or any extra consideration over the agreed price. In the absence of cogent reasons undermining the declared value, enhancement of assessable value on contemporaneous import data alone was unjustified. The earlier similar view remaining undisturbed also supported adherence to that approach, and the assessee succeeded while the department's appeals failed.

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Issues: Whether the declared transaction value of imported mulberry raw silk could be rejected and enhanced merely on the basis of contemporaneous imports and past acceptance of a higher value.

Analysis: The declared invoice value was supported by the contract documents and the department did not establish any discrepancy in the contract, any relationship between the parties, or any receipt of consideration over and above the agreed price. Enhancement of value rested only on contemporaneous import data, without cogent reasons for discarding the transaction value. The quantity contracted, commercial terms, and surrounding circumstances were relevant factors affecting price, and mere reliance on higher contemporaneous imports was insufficient to reject the declared value. The earlier order in a similar case had also taken the same view and had been left undisturbed, warranting adherence to that approach.

Conclusion: The rejection of the transaction value and the enhancement of assessable value were unjustified; the assessee succeeded and the department appeals failed.

Ratio Decidendi: Transaction value cannot be rejected or enhanced merely because contemporaneous imports show a higher price unless the department establishes cogent reasons undermining the declared value.

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