Customs applied method 6 (fallback), arguing that the $620,000 price was lower than the "average market" price. We analysed the customs database and found that the "average market" value had been calculated for goods of a different class — general-purpose servers — whereas our client was importing specialised data-centre components with unique technical characteristics.
In the administrative complaint we proved that:
- The price is genuine and confirmed by a SWIFT transfer.
- The goods have unique specifications with no direct equivalents in the customs database.
- The discount is justified by the purchase volume and the long-standing relationship with the supplier.
Customs revoked the decision. The key argument: non-identical goods cannot be compared.