Questão jurídica principal
Whether the appellant could rely on good faith to avoid subsequent customs duties after importing before paying the auction price.
Decisão extraída
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.
Fundamentação extraída
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.