Customs valuation must rest on comparable imports; declared transaction value cannot be rejected on non-comparable foreign-source price comparisons.

Customs transaction value cannot be rejected merely by comparing imported goods with contemporaneous imports from a different country of origin. Where no comparable imports from the same source are shown and no legally sufficient basis exists to discard the declared price, the declared transaction value must be accepted under the valuation rules. The note therefore confirms that general price comparisons with non-comparable imports do not justify enhancement of assessable value, and the declared import price stands.

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Issues: Whether the declared transaction value of imported goods could be rejected on the basis of contemporaneous imports of goods said to be similar but sourced from a different country.

Analysis: The imported goods were compared with imports from a different country of origin, and the absence of contemporaneous imports from the same country was found to be material. In the absence of comparable imports from the same source, and in light of the principles governing customs valuation, the declared transaction value could not be discarded merely on a general comparison of prices. The reasoning was consistent with the valuation rules and the settled approach that transaction value is not to be rejected without adequate legal basis.

Conclusion: The declared value was correctly accepted and the Revenue's attempt to enhance valuation was rejected.

Final Conclusion: The appeal failed, and the order accepting the declared import price stood confirmed.

Ratio Decidendi: Transaction value under the customs valuation scheme cannot be rejected on the basis of non-comparable imports, particularly where the alleged contemporaneous imports are from a different country of origin and no legally sufficient basis for discarding the declared value is established.

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