Transaction value in customs valuation must be accepted absent relationship, abnormal consideration, or reliable contrary evidence.

Declared transaction value of imported polystyrene resin had to be accepted for customs valuation where the authorities relied only on comparable import prices and speculative market assumptions. No relationship between supplier and importer, no abnormal consideration, and no reliable evidence of undervaluation or foreign exchange remittance was shown. Contemporaneous invoices and the supplier's certificate supported the declared price, including a later reduction in price. On that record, the declared value could not be rejected, and enhancement of assessable value was unsustainable under the Customs Valuation Rules.

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Issues: Whether the declared invoice value of the imported polystyrene resin could be rejected and enhanced for customs valuation, or whether the transaction value had to be accepted under the valuation rules.

Analysis: The Customs authorities relied on comparable import prices and treated the declared price as inconsistent with the market, but no basis was established for the assumption that high impact polystyrene was necessarily costlier than general purpose polystyrene. There was also no finding of any remittance of foreign exchange abroad or any relationship between the supplier and the importer. The material on record, including contemporaneous invoices and the supplier's certificate indicating the declared price and later reduction in price, supported the appellants' declared value. In these circumstances, the transaction value could not be discarded merely on speculative comparison with other imports.

Conclusion: The declared value was required to be accepted under Section 14(1A) read with Rule 4 of the Customs Valuation Rules, 1988, and the enhancement of assessable value was unsustainable.

Ratio Decidendi: Where no relationship, abnormal consideration, or reliable contrary evidence is shown, the declared transaction value of imported goods must be accepted for customs valuation and cannot be rejected on unsupported comparison with other import prices.

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