Customs valuation depends on statutory relationship proof and genuine comparability before declared value can be rejected.

For customs valuation, persons are related only if they fall within the statutory categories such as common ownership, control, partnership, or employer-employee relationship; mere use of a logo or prior dealings is insufficient. The department also cannot reject the declared value by relying on a higher price from another import unless true comparability is established. Where the importer shows the goods were stock lot goods and the lower price is commercially explained by a distressed sale, and the department adduces no contrary evidence, enhancement of value is not justified.

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Issues: (i) Whether the importer and the foreign seller were related persons for valuation purposes. (ii) Whether the imported goods, being stock lot goods, could be compared with another import to enhance the declared value.

Issue (i): Whether the importer and the foreign seller were related persons for valuation purposes.

Analysis: Rule 2(2) of the Customs Valuation Rules treats persons as related only in specified situations such as corporate control, common ownership, partnership, or employer-employee relationship. The department did not establish that the appellant and the seller fell within any of those categories. Mere use of a logo or prior business dealings was not enough to prove relationship for valuation purposes.

Conclusion: The importer and the seller were not related persons; the department's valuation objection on that basis failed.

Issue (ii): Whether the imported goods, being stock lot goods, could be compared with another import to enhance the declared value.

Analysis: The correspondence from the supplier supported the claim that the goods were stock lot. Once stock lot character is accepted, a reduced price is commercially explained by the nature of a distressed sale. The department did not adduce evidence to disprove this claim. The higher price of an allegedly identical import by another importer did not by itself justify enhancement, particularly when the goods were not shown to be truly comparable.

Conclusion: The declared value could not be enhanced on the basis of the other import; the goods were not shown to be comparable.

Final Conclusion: The valuation enhancement was set aside and the appeal succeeded with consequential relief.

Ratio Decidendi: For customs valuation, relationship between parties must be proved within the statutory categories, and a declared value cannot be rejected merely because another import of apparently similar goods fetched a higher price when the goods are shown to be stock lot goods and comparability is not established.

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