Rejection of Imported Goods' Transaction Value Unjustified Due to Different Quantities, Violating Rule 5 Valuation Criteria.

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....Valuation of imported goods - The only ground on the basis of which the transaction value has been rejected is that the imports were made at a higher price by other importers than at the price at which the Appellant imported HR Coils in question - A perusal of the imports relied upon in the impugned order show that the quantity of imports were substantially different from the quantity of the import made by the Appellant. Rule 5 of the Valuation Rules requires, amongst others, that the transaction value of identical goods should be at the same commercial level and in substantially the same quantity as the goods being valued to determine the value of the imported goods. In the present case neither the goods were identical nor of substantially the same quantity. - AT....