Declared transaction value must be accepted absent Rule 4(2) grounds; contemporaneous imports alone do not justify rejection.

Declared transaction value for imported goods cannot be rejected unless the specific grounds in Rule 4(2) of the Customs Valuation Rules are clearly established. Mere reliance on contemporaneous imports, without identifying a valid basis for rejection, is insufficient. Where the record shows no extra amount paid over the declared price and the price arises from a forward contract, the contracted value supports acceptance for customs duty purposes. An earlier decision was held inapplicable because it concerned the position before amendment of Section 14 of the Customs Act, so the declared value was to be accepted.

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Issues: Whether the declared transaction value for the imported goods could be rejected and whether the appellants were entitled to acceptance of the declared value for customs duty purposes.

Analysis: Rejection of transaction value requires clear satisfaction of the circumstances specified in Rule 4(2) of the Customs Valuation Rules. Mere reliance on contemporaneous imports, without identifying the specific legal ground for rejection, was insufficient. The record also did not show that any extra amount had been paid over and above the declared price. The declared price was stated to arise from a forward contract, which supported acceptance of the contracted value. The reliance placed on an earlier decision was found inapplicable as it related to the position prior to amendment of Section 14 of the Customs Act.

Conclusion: The rejection of the declared transaction value was unsustainable and the declared value was to be accepted for customs duty purposes.

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