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Issues: Whether Resin Bonded Bamboo Mats with Veneer in between were classifiable under Heading 4410.90 as articles of wood or under Heading 4408.90 as laminated wood, and whether the earlier unchallenged Tribunal order governed the dispute.
Analysis: The dispute turned on the proper application of Chapter Note 6 to Chapter 44 of the Central Excise Tariff Act, 1985. The earlier Tribunal order had already held that the product fell under Heading 4410.90, and that order was not challenged by the Revenue. In these circumstances, the prior finding was binding on the lower authorities, and the Tribunal could not re-open the matter in appeal over its own earlier decision. The Revenue's objection that the note relied upon was not in force for the relevant period did not alter the binding effect of the unassailed earlier order.
Conclusion: The goods were held classifiable under Heading 4410.90, and the Revenue's appeal failed.
Ratio Decidendi: An unchallenged prior Tribunal decision on classification binds the lower authorities and cannot be disregarded in subsequent proceedings on the same dispute.