Retrospective reclassification under a later circular was impermissible where the earlier approved classification had already been completed.

Completed classification approved under the then-applicable Board circular could not be altered retrospectively on the basis of a later circular. The goods had already been classified under Tariff Heading 9029.00, and the subsequent change in the Board's view did not justify disturbing the completed assessments for the disputed period. Following the pre-existing circular, retrospective reclassification was held impermissible, and the resulting demand could not be sustained.

---

---

Issues: Whether the classification of the goods could be altered retrospectively on the basis of a subsequent Board circular when the earlier classification had already been approved.

Analysis: The assessments had been completed on the basis of the Board circular then in force and the classification list had already been approved under Tariff Heading 9029.00. A later change in the Board's view and the issue of a fresh circular could not be applied to disturb the completed classification for the period in dispute. The earlier decision cited by the assessee, following the pre-existing circular, supported the view that reclassification on the basis of the impugned circular was not justified.

Conclusion: The retrospective reclassification was not permissible and the demand could not be sustained.

---