Final classification bars fresh differential duty demand when the issue has already attained finality.

Where classification of a product has already been finally settled in favour of the assessee, a fresh demand for differential duty on a contrary classification cannot survive. The Tribunal noted that the classification dispute had been conclusively decided and affirmed by the Supreme Court, and that a later assessment under the assessee's claimed heading had also attained finality without challenge. On that basis, the authorities treated the classification issue as closed and refused to sustain a renewed demand. The differential duty demand was therefore held unsustainable and the Revenue's challenge failed.

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Issues: Whether the demand for differential duty could survive after the classification of the product had already been finally decided in favour of the assessee.

Analysis: The classification controversy had been conclusively settled by the Tribunal and that decision had been affirmed by the Supreme Court. The later assessment of the same product under the assessee's claimed heading had also been finalised, and no challenge was pursued against that order. In these circumstances, the authorities below correctly treated the classification issue as closed and declined to sustain a fresh demand for differential duty based on a contrary classification.

Conclusion: The demand for differential duty was not sustainable and the Revenue's challenge failed.

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