Customs valuation cannot ignore declared transaction value merely because a price list exists when invoice genuineness is undisputed.

In customs valuation, the declared transaction value of imported bearings could not be rejected merely because the Department relied on the supplier's price list. The accompanying forwarding letter showed that the 20% discount was not fixed or maximum and that higher discounts could be granted case by case. As the authorities did not dispute the genuineness of the supplier's invoice, the actual purchase price remained the proper basis of assessment. The rejection of the transaction value was therefore unjustified, the valuation order was set aside, and consequential relief followed.

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Issues: Whether the customs authorities were justified in rejecting the declared transaction value of imported bearings and in relying on the supplier's price list to assess value.

Analysis: The declared value could not be discarded merely because the Department relied on a manufacturer's price list. The forwarding letter accompanying the price list showed that the 20% discount was not the maximum discount and that higher discounts could be granted on a case-to-case basis. In that setting, the fact that the supplier procured the goods at prices lower than the list price less 20% did not render the import value unacceptable. The price list was not enough to override the actual purchase price, and the authorities had not found the supplier's invoice to be false or non-genuine.

Conclusion: The rejection of the transaction value was not justified, and the declared value had to be accepted.

Final Conclusion: The impugned valuation order was set aside and the appellant obtained consequential relief.

Ratio Decidendi: In customs valuation, the declared transaction value cannot be ignored merely on the basis of a price list where the surrounding documents show that the quoted discount was not fixed or maximum and the genuineness of the purchase invoice is not disputed.

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