Transaction value for second-hand machinery prevails unless Rule 4 rejection grounds are proved; a certificate error was insufficient.

In valuation of imported second-hand machinery, transaction value under the Customs Valuation Rules remains the primary basis and may be rejected only on the statutory grounds recognised in Rule 4, such as proof that the invoice is not genuine or that the price is otherwise vitiated. An incorrect year of manufacture in the Chartered Engineer's certificate, by itself, did not establish fraud, abnormal consideration, or any other disqualifying circumstance. Resort to best judgment valuation under Rule 8 was therefore not permissible, and the declared invoice value had to be accepted.

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Issues: Whether the declared transaction value of imported second-hand machinery could be rejected merely because the Chartered Engineer's certificate mentioned an incorrect year of manufacture, and whether valuation could then be proceeded with under Rule 8 instead of accepting the invoice value under Rule 4.

Analysis: Section 14 of the Customs Act and Rules 3 and 4 of the Customs Valuation Rules give primacy to transaction value. The transaction value can be discarded only when the circumstances for rejection under Rule 4 are established, such as restrictions on disposition, conditions affecting price, related-party influence, or proof that the invoice is not genuine. In the present case, the only infirmity pointed out was an error in the year of manufacture in the Chartered Engineer's certificate. That error, by itself, did not establish fraud, clandestine payment, abnormal consideration, or any other ground recognised by Rule 4. The fact that the machinery was second-hand did not exclude application of transaction value. In the absence of evidence justifying rejection of the invoice price, resort to best judgment under Rule 8 was not permissible.

Conclusion: The declared transaction value had to be accepted, and rejection of the invoice value merely because of the incorrect year in the certificate was unjustified.

Ratio Decidendi: In valuation of imported second-hand goods, transaction value under Rule 4 remains the primary basis and cannot be rejected unless the statutory grounds for rejection are proved; an error in supporting documents, without evidence of fraud or other disqualifying circumstances, does not justify resort to Rule 8.

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