Classification change without recorded reasons cannot stand; remand ordered for fresh adjudication after hearing the appellants.

A classification change from Heading 2621 to Heading 2811.90 could not be sustained where the Commissioner (Appeals) reversed the original view without recording plausible reasons. The product had been consistently declared under Heading 2621 and the manufacturing process remained unchanged, so the unexplained shift in classification was treated as an improper adjudication on classification. The classification order was therefore set aside, and the matter was remanded for de novo adjudication after granting the appellants a reasonable opportunity of hearing.

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Issues: Whether the change in classification of the product from Heading 2621 to Heading 2811.90 could be sustained without recording reasons, and whether the matter required remand for fresh adjudication.

Analysis: The appellant had consistently filed declarations classifying the product under Heading 2621, and the process of manufacture had remained unchanged. The order of the Commissioner (Appeals) reversed the original decision and accepted the Revenue's classification without any plausible explanation for the change. Such a reversal, in the absence of recorded reasons, could not be sustained as a proper adjudication on classification.

Conclusion: The classification order was set aside and the matter was remanded for de novo adjudication after granting a reasonable opportunity of hearing to the appellants.

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