Key legal question
Whether the appellant could rely on good faith to avoid subsequent customs duties after importing before paying the auction price.
Extracted holding
No. The auction decision and the relevant ordinance clearly required prior payment, so the appellant could not reasonably believe it was authorized to import at the quota rate before payment.
Extracted reasoning
The court held that the prior-payment condition was expressly stated in the decision, the ordinance, and the tender notice; no special circumstances justified a contrary interpretation.