Valuation principle: amendment treating discounted sales without buyer consideration as transaction value raises statutory conflict.
Amendment to Rule 6 adds a proviso deeming sales below manufacturing cost to be transaction value when no additional consideration flows from the buyer, creating an internal contradiction because the phrase "price is not the sole consideration" presumes additional consideration that, if present, should be added to declared value; this tension with the main clause and the statutory valuation provision suggests the proviso may be conceptually flawed and ultra vires. (AI Summary)
Amendment to Rule 6 adds a proviso deeming sales below manufacturing cost to be transaction value when no additional consideration flows from the buyer, creating an internal contradiction because the phrase "price is not the sole consideration" presumes additional consideration that, if present, should be added to declared value; this tension with the main clause and the statutory valuation provision suggests the proviso may be conceptually flawed and ultra vires. (AI Summary)
TaxTMI