Declared transaction value in customs valuation cannot be rejected solely because another import fetched a higher price.

Declared transaction value for imported non-calcined petroleum coke cannot be rejected merely because a comparable import shows a higher price. The valuation analysis turns on whether the comparison import is a reliable benchmark under customs rules; here, materially different commercial arrangements, including a long-term large-quantity contract versus a one-off smaller shipment, explained the lower declared price. In the absence of material indicating misdeclaration or another legally sustainable basis, the invoice value should be accepted and value enhancement on the comparable import fails.

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Issues: Whether the declared transaction value of the imported non-calcined petroleum coke could be rejected and the value of a comparable import adopted for assessment.

Analysis: The appeal turned on whether the comparison import was a reliable benchmark under the customs valuation framework. The goods were of the same description, but the imports were under materially different commercial arrangements. The respondent's imports were under a long-term contract for a very large quantity, while the comparable import was a one-off shipment in a much smaller quantity. The difference in quantity, contract timing, and commercial terms explained the lower declared price, and there was no material showing misdeclaration or other basis to discard the invoice value. In these circumstances, the comparable import was not a proper basis to reject the declared value under the valuation rules.

Conclusion: The declared transaction value was held to be acceptable, and the attempt to enhance value on the basis of the comparable import failed.

Final Conclusion: The departmental challenge to the valuation was rejected, and the assessment was left to proceed on the declared value.

Ratio Decidendi: Under customs valuation law, declared transaction value cannot be rejected merely because a higher price appears in another import; rejection requires a legally sustainable basis, and commercial differences such as quantity, contract terms, and timing may justify a lower declared value.

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