Transaction value for customs valuation stays tied to the original contract price, not a post-import price reduction.

Transaction value for customs valuation under Rule 4 remains anchored to the price of the goods actually contracted for at the time of import. A post-import addendum reducing the ship's price did not alter assessable value because the original memorandum described an outright sale on an "as is where is" basis, and the asserted defects did not show that the vessel delivered was materially different from the vessel contracted for. Where no contractual basis for a reduced price exists and the price reduction arises only after import, the original agreed price continues to govern assessment.

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Issues: Whether the import value of the ship could be assessed on the reduced price mentioned in the post-import addendum to the memorandum of agreement, or on the original agreed price under the transaction value rule.

Analysis: Transaction value under Rule 4 is the governing basis for assessment, but it must reflect the price of the goods actually contracted for at the time of import. The original memorandum of agreement described an outright sale on an "as is where is" basis and contained the agreed description of the vessel. The alleged defects relied upon in the addendum did not show that the goods delivered were different from the goods contracted to be bought and sold, nor did the agreement provide for a price reduction on those grounds. The reduction was made after import, whereas customs valuation is concerned with the price of the goods at the time they are imported into India.

Conclusion: The reduced price in the addendum was not able for customs valuation, and the original agreed price remained the assessable value.

Final Conclusion: The appeal succeeded and the assessment based on the original price was restored.

Ratio Decidendi: A post-import reduction in contract price cannot displace the transaction value for customs assessment unless the goods imported are shown to be materially different from the goods contracted for.

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