Transaction value in customs valuation cannot be rejected solely because contemporaneous imports were priced higher.

For customs valuation, the declared transaction value of imported goods remains the basis of assessment unless there is a valid reason to doubt that it represents a full commercial price. A higher price in another contemporaneous import does not, by itself, justify rejection of the declared value or enhancement of assessable value. Where the importer's explanation for price variation, such as differences in contracted quantities, is consistent with commercial practice and not shown to be false or unsupported, the transaction value should be accepted. The note concludes that contemporaneous higher import prices alone are insufficient to discard the declared value.

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Issues: Whether the declared transaction value of imported goods could be rejected and the assessable value enhanced merely because contemporaneous imports were available at higher prices.

Analysis: Rule 4 of the Customs Valuation Rules makes the transaction value in the particular import the basis of assessment. A higher price in another contemporaneous import is not, by itself, a valid reason to discard the declared price. Rejection of the transaction value requires a reason to doubt whether the declared price represents a full and commercial price. The explanation that the price variation arose from differences in contracted quantities was consistent with commercial practice and was not shown to be false or unsupported.

Conclusion: The higher contemporaneous import prices did not justify rejection of the declared transaction values. The enhancement of assessable value was unsustainable and the appeal succeeded.

Ratio Decidendi: For customs valuation, the transaction value of the goods under assessment must be accepted unless there is a valid reason to doubt that it is a full commercial price; higher prices in other contemporaneous imports do not, by themselves, warrant rejection of that value.

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