Binding Larger Bench classification for identical goods supports Heading 8504.00 over competing tariff classification

UPSS was classified under Chapter Heading 8504.00 rather than Chapter Heading 8543.00 because the tribunal followed a binding Larger Bench ruling that had already placed the identical product under Heading 8504.00. The prior authoritative classification controlled the present dispute, so the assessee's classification claim was accepted and the Department's contrary appeal failed on that issue.

---

---

Issues: Whether UPSS was classifiable under Chapter Heading 8504.00 or under Chapter Heading 8543.00.

Analysis: The classification dispute was resolved by following the Larger Bench decision which had held the same item to fall under Chapter Heading 8504.00. In view of that binding ratio, the assessee's classification claim was accepted.

Conclusion: UPSS was held classifiable under Chapter Heading 8504.00, in favour of the assessee.

Final Conclusion: The assessee's appeal succeeded on classification, and the Department's appeal did not survive once that issue was decided against it.

Ratio Decidendi: Where a Larger Bench has authoritatively classified the same product under a particular tariff heading, the same classification is to be followed in subsequent cases involving the identical item.

---