Customs transaction value cannot be rejected on suspicion without cogent evidence discrediting the declared price.

Declared customs transaction value may not be rejected on suspicion or broad allegations of abnormal pricing unless the Department produces cogent evidence showing that the stated price is not genuine. The absence of a written purchase order or exact letter of credit coverage, by itself, was held insufficient to displace the importer's declared value. Reliance on contemporaneous imports also failed because the Department did not furnish the necessary particulars of comparable transactions. The declared value was therefore accepted and the proposed enhancement was not sustained.

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Issues: Whether the declared transaction value of the imported goods could be rejected and enhanced on the basis of alleged lack of purchase order, letter of credit coverage, contemporaneous imports, and purportedly abnormal price reduction.

Analysis: The Department did not produce evidence of any extra payment to the foreign seller or any material showing that the declared price was not the genuine transaction value. The absence of a written purchase contract or exact coverage in the letter of credit was not treated as sufficient, by itself, to displace the importer's declared value. The reliance on contemporaneous imports was also found inadequate because the necessary particulars of comparable imports were not furnished.

Conclusion: The declared value was accepted and the proposed enhancement was not sustained; the Department's appeal failed.

Ratio Decidendi: A declared customs transaction value cannot be rejected merely on suspicion or on general allegations of abnormal pricing unless the Department produces cogent evidence discrediting the genuineness of the declared price.

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