Transaction value controls customs valuation unless a statutory exception applies; market guides cannot override the declared price.

Declared transaction value is the primary basis for customs valuation of imported goods under the Customs Act and Customs Valuation Rules, and it may be displaced only where a recognised statutory exception applies or the value cannot be determined under the primary rule. External market references such as Parker's Guide cannot be used to ignore the actual price paid merely because the authorities consider them more appropriate. Applying the principle in Eicher Tractors, the declared transaction value of the imported second-hand car had to be accepted, and the enhanced valuation based on market data could not stand.

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Issues: Whether the declared transaction value of the imported second-hand car had to be accepted under Rule 4 of the Customs Valuation Rules, 1988, or whether the customs authorities could ignore that value and adopt a higher valuation on the basis of market data such as Parker's Guide.

Analysis: Section 14(1) of the Customs Act, 1962 deems the value of imported goods to be the price ordinarily realised in international trade, and Section 14(1A) requires determination of imported-goods value in accordance with the valuation rules. Rule 3 makes transaction value the primary method, and Rule 4(1) treats the price actually paid or payable as the transaction value. That mandate can be displaced only if the case falls within the exceptions in Rule 4(2) or if the value cannot be determined under Rule 4(1) and the authorities proceed to the alternative methods. Applying the principle stated in Eicher Tractors, the authorities cannot disregard the actual price paid merely because they consider external market data more appropriate, unless a recognised statutory exception is established.

Conclusion: The declared transaction value was required to be accepted, and the enhanced valuation based on the Parker's Guide could not stand.

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