Genuine manufacturer's invoice prevails over quotations when no reliable contemporaneous higher-priced imports are shown.

Where the manufacturer's invoice is found genuine, it is the best evidence of transaction value under the valuation rules, and the declared price should be accepted. Quotations or alleged comparable prices cannot by themselves justify enhancement of assessable value unless supported by reliable evidence of contemporaneous imports of identical or similar goods at a higher value. On the materials described, the invoice price was treated as valid and the proposed enhancement was unsustainable on quotations alone.

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Issues: Whether the manufacturer's invoice for the imported goods was genuine and constituted the proper basis for assessable value, and whether quotations and alleged comparable prices could justify enhancement of value.

Analysis: The importer produced the manufacturer's invoice and supporting material showing that the goods were sold through the export arrangement prevailing in China. On the materials placed before it, the invoice issued in the transaction chain was accepted as the genuine manufacturer's invoice. Once that invoice was found reliable, it became the best evidence of the transaction value under the valuation rules. The quotations relied upon for enhancement were treated as mere offers and not as evidence of actual imports or concluded transactions, and therefore could not displace the declared invoice price in the absence of contemporaneous imports of identical or similar goods at a higher value.

Conclusion: The manufacturer's invoice was held to be genuine, the declared price was accepted, and the enhancement of assessable value was unsustainable.

Final Conclusion: The appeal succeeded and the valuation order was set aside, with the import value being determined on the basis of the accepted invoice price rather than on quotations or notional market comparisons.

Ratio Decidendi: Where the manufacturer's invoice is found genuine and there is no reliable evidence of contemporaneous higher-priced imports, the declared transaction value cannot be rejected on the basis of quotations alone.

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