Customs valuation must follow ordinary market price, and a special discount may be rejected for assessment where evidence supports the ruling price.

Customs valuation under Section 14(1) turns on the ordinary international trade price of the goods, not a special concession or discounted invoice price granted only to one buyer. On the recorded facts, the supplier's correspondence showed US$ 34,000 as the ruling price and US$ 28,000 as a special price in the petitioner's case, so the authorities were justified in adopting US$ 34,000 for assessment. The court also noted that such factual findings, being supported by evidence and representing a possible view, are not ordinarily open to interference in writ jurisdiction absent an error of law or a finding with no evidence.

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Issues: Whether the customs authorities were justified in valuing the imported machine at US$ 34,000 under Section 14(1) of the Customs Act, 1962 and Rule 8 of the Customs Valuation Rules, 1963, notwithstanding the invoice price of US$ 28,000 claimed as a special discount.

Analysis: The value under Section 14(1) is to be determined with reference to the price at which such or like goods are ordinarily sold or offered for sale in the course of international trade. On the findings recorded by the authorities, the reduction to US$ 28,000 was a special case discount and not the ordinary price of the machine. The supplier's correspondence showed that US$ 34,000 was the ruling price and that US$ 28,000 was a special price allowed only in the petitioner's case. Those findings were factual, and the view taken by the authorities was a possible view. In writ jurisdiction, such findings could not be reappreciated unless there was an error of law apparent on the face of the record or a finding based on no evidence.

Conclusion: The valuation at US$ 34,000 was upheld and the challenge failed.

Ratio Decidendi: For customs valuation under Section 14(1), the determinative price is the ordinary market price of the goods in international trade, and a special concession or discounted price extended only as an exception need not be accepted for assessment purposes; factual findings supported by evidence are not normally open to interference in writ jurisdiction.

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