Customs transaction value cannot be rejected merely because e-commerce prices appear higher; declared value remains binding absent special circumstances.

Declared transaction value for imported goods must be accepted where no special circumstances justify rejection under Section 14(1) of the Customs Act, 1962 read with Rule 3 of the Customs Valuation Rules, 2007. Prices displayed on e-commerce websites, by themselves, do not constitute contemporaneous value sufficient to displace the price actually paid to the supplier. Applying that settled valuation principle, the lower authority's acceptance of the declared value was sustained and the Revenue's basis for rejection was found unsustainable. The valuation based on transaction value therefore remained undisturbed.

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Issues: Whether the declared transaction value of imported goods could be rejected on the basis of prices shown on e-commerce websites, and whether the order of the lower authority upholding transaction value was liable to be disturbed.

Analysis: The disputed goods had already been released, and no statutory basis existed to grant stay of the impugned order. On merits, the lower authority found that prices taken from e-commerce websites could not be treated as contemporaneous value for rejecting the transaction value. The impugned order also applied the settled legal position that, in the absence of special circumstances contemplated by Section 14(1) of the Customs Act, 1962 read with Rule 3 of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007, the price actually paid to the supplier is to be accepted as the transaction value.

Conclusion: The rejection of the transaction value on the basis suggested by Revenue was not sustainable, and the impugned order was upheld.

Final Conclusion: The appeal failed on merits, and the valuation based on the declared transaction value was left undisturbed.

Ratio Decidendi: In the absence of special circumstances justifying rejection of declared value, the transaction value must be accepted and cannot be displaced merely by reference to higher prices reflected on e-commerce platforms.

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