Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade price.

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....Transaction value rules for related persons require that declared invoice value be accepted only if the relationship did not influence price; the relevant valuation standard is the price at which such or like goods are ordinarily sold for delivery at time and place of importation, not merely the actual inter-party price. The importer bears the burden of proving declared value closely approximates contemporaneous market comparators and that discounts do not reflect relationship-driven pricing; absence of profit element or inability to show cost recovery supports rejection of the declared value under the valuation rules.....