Air-conditioning ducts as system parts cannot be reclassified under sub-heading 7304.10 when binding precedent already settles the issue.

Ducts manufactured and supplied for air-conditioning projects were treated as part of the air-conditioning system rather than classifiable under sub-heading 7304.10, because the Tribunal found the issue already covered by binding precedent in the assessee's own case and connected rulings. It also relied on the Supreme Court's dismissal of the Department's appeal in that matter. On that basis, the classification adopted in the impugned orders could not be sustained, and the related duty demand and consequential penalty on the chief executive were set aside.

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Issues: Whether the ducts manufactured and supplied in connection with air-conditioning projects were classifiable as parts of the air-conditioning system rather than under sub-heading 7304.10, and whether the duty demand and penalties could survive in view of the binding precedent in the assessee's own case.

Analysis: The Tribunal noted that the dispute stood covered by its earlier decisions in the assessee's own case and by other connected rulings, which had treated the ducts as part of the air-conditioning system. The Tribunal also relied on the Supreme Court's dismissal of the Department's appeal against the assessee's own case. In light of that binding position, the classification adopted in the impugned orders could not be sustained. Once the duty demand failed, the penalty imposed on the chief executive of the assessee-firm also had no independent footing.

Conclusion: The ducts were not liable to be classified under sub-heading 7304.10 as demanded in the impugned orders, and the duty and consequential penalties were set aside in favour of the assessee.

Ratio Decidendi: Where an issue is already concluded by binding precedent, including in the assessee's own case, the same classification cannot be reopened and any duty demand and consequential penalty based on that classification must fail.

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