Transaction value in customs valuation cannot be rejected merely on higher contemporaneous import prices without statutory grounds.

Declared import value supported by the manufacturer's invoice cannot be discarded merely because contemporaneous imports of the same goods show higher prices. Under the Customs Valuation Rules, transaction value may be rejected only when the statutory grounds for rejection are established; mere reliance on other invoices is insufficient. On the stated facts, the declared transaction value was not sustainable to reject, and the importer's valuation position prevailed.

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Issues: Whether the declared value of imported goods could be rejected merely on the basis of contemporaneous imports and whether the transaction value was validly discarded under the Customs Valuation Rules.

Analysis: The importer declared a value supported by the manufacturer's invoice, while the department rejected it by comparing prices in contemporaneous imports of the same goods. The record showed that the department had not established the specific grounds required for rejection of transaction value under the valuation rules. Mere reliance on higher prices in other invoices, without more, was held insufficient to displace the declared transaction value.

Conclusion: The rejection of the declared value was not sustainable and the appeal succeeded.

Ratio Decidendi: Transaction value cannot be rejected solely on the basis of contemporaneous import prices of the same goods unless the statutory grounds for rejection are established.

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