Customs valuation depends on the original export sale price, not a later post-import price reduction.

For customs valuation, the transaction value must reflect the price actually paid or payable for the sale that gave rise to importation into India. A lower price negotiated only after the goods had already been imported, landed and unloaded could not replace the original export sale price for assessment purposes. Contemporaneous price data also supported the Department's valuation. The assessable value was therefore correctly based on the original sale price agreed for export to India, and the later post-import arrangement did not affect customs duty valuation.

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Issues: Whether the declared transaction value of imported goods could be rejected and the assessable value taken at the higher price at which the goods had originally been shipped for export to India.

Analysis: The negotiated lower price was agreed after the goods had already been imported, landed, and unloaded in India. Under Rule 4 of the Valuation Rules, the transaction value is the price actually paid or payable for the goods when sold for export to India, and the relevant price is the price that gave rise to the importation. The original sale to the first buyer at US $ 1045 PMT was the sale for export to India, whereas the later reduced price was a post-import arrangement and not the basis for customs valuation. The contemporaneous price data also supported the Department's valuation.

Conclusion: The declared value was not acceptable, and the assessable value was rightly determined on the basis of the original export sale price.

Final Conclusion: The valuation adopted by the customs authorities was sustained and the appeal failed.

Ratio Decidendi: For customs valuation, the transaction value is the price of the sale that gives rise to the importation into India, and a price negotiated only after importation cannot displace that value.

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