Classification beyond show-cause notice was impermissible; the matter was remanded for fresh decision on the disputed headings.

The appellate authority could not classify the goods under a tariff entry outside the dispute framed in the show-cause notice, because the classification controversy was limited to two competing headings. By selecting a third entry, the authority exceeded the scope of the notice and acted beyond the permissible issues. The order was therefore set aside, and the matter was remanded to the lower appellate authority for fresh decision on the classification dispute in accordance with law and the principles of natural justice.

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Issues: Whether the appellate authority could classify the goods under an entry outside the dispute raised in the show-cause notice and whether the matter required remand for fresh decision.

Analysis: The classification controversy before the appellate authority was confined to competing claims under two headings. By choosing a third entry, the appellate authority travelled beyond the scope of the dispute arising from the show-cause notice. Such a course was held impermissible, and the matter was required to be reconsidered afresh in accordance with law and the principles of natural justice.

Conclusion: The impugned order was set aside and the case was remanded to the lower appellate authority for fresh decision on the classification dispute.

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