By S&S Co. Advocates & Solicitors · Published 30 May 2026 · Informational content, not legal advice
About this article: A general explainer prepared by S&S Co. Advocates & Solicitors on a recurring type of dispute. It does not report a specific judgment or order, names no parties and gives no case citation, so it should not be cited as authority. Law and practice change; please verify against the current statute and primary sources before relying on it.
Under the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007, imported goods are valued at their transaction value. Where the buyer and seller are related, Rule 3 allows the transaction value to be accepted only if the relationship has not influenced the price. Customs authorities, including the Special Valuation Branch (SVB), examine related-party imports for this purpose.
The fact of a relationship is not, by itself, a ground to reject the declared value or to add a loading. The importer can show that the price is consistent with the price charged to unrelated buyers for identical or similar goods at about the same time, or with a deductive or computed value. Supporting material such as comparable third-party invoices and a transfer pricing study is commonly offered.
A centralised group pricing policy does not by itself show that the relationship influenced the price, since multinational groups commonly price on a group-wide basis for commercial reasons. Where the importer produces credible comparables and the department produces no contrary material, the department's rejection of the value is open to challenge in appeal. The outcome depends on the evidence in each case.