Classification of Dhanzyme as a bio-fertiliser under tariff sub-heading 3101.00 was followed based on prior Tribunal ruling.

Dhanzyme was treated as classifiable under sub-heading 3101.00 of the Central Excise Tariff Act, 1985 as a plant growth promoter and bio-fertiliser. The text notes that the classification issue had already been settled in an earlier Tribunal decision involving the same product, and that prior view was followed because no distinguishing feature was shown. The operative principle is that an established classification for the same product should be applied consistently where the facts and product description remain unchanged.

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Issues: Whether Dhanzyme is classifiable under sub-heading 3101.00 as a plant growth promoter / bio-fertiliser.

Analysis: The classification dispute was already settled in an earlier Tribunal decision involving the same product, where Dhanzyme was held to be a bio-fertiliser and a plant growth promoter falling under sub-heading 3101.00 of the Central Excise Tariff Act, 1985. Following that binding view, no infirmity was found in the order under challenge.

Conclusion: Dhanzyme was held classifiable under sub-heading 3101.00 of the Central Excise Tariff Act, 1985 as a plant growth promoter / bio-fertiliser, and the Revenue's appeals were rejected.

Ratio Decidendi: Where the classification issue has already been settled by a prior Tribunal decision on the same product, the same classification is to be followed absent any distinguishing feature.

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