Comparable import prices may support customs valuation where goods match in quality and no material price drop is shown.

Comparable import prices can be used to enhance declared value where the imported aniseeds are shown to be of the same broken quality as the relied-upon consignments. A gap of about four months between the disputed import and the comparable transactions did not, by itself, make the prices unusable, because there was no evidence of a drastic fall in prices. On that basis, the contemporaneous import evidence was accepted for valuation and the enhancement of value was upheld.

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Issues: Whether the declared value of the imported aniseeds could be enhanced on the basis of contemporaneous imports and other price materials, and whether the difference in quality or the gap in time made the relied-upon imports non-comparable.

Analysis: The goods under dispute were found to be of the same broken quality as the goods covered by the relied-upon invoices, so the objection that the comparable imports related only to whole quality goods was rejected. The gap of about four months between the disputed import and the comparable transactions was held not, by itself, sufficient to discard those prices in the absence of evidence of a drastic fall in prices. The lower authorities' reliance on the contemporaneous import evidence was therefore sustained.

Conclusion: The enhancement of value was upheld and the appeal failed.

Ratio Decidendi: Comparable import prices may be relied upon for valuation where the goods are shown to be of the same quality, and mere lapse of time without evidence of material price fluctuation does not render the comparable transactions inapplicable.

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