MRP-based excise valuation applies to packaged refrigerators even when sold in bulk to institutional buyers.

Refrigerators cleared in packaged form with MRP declaration were treated as goods liable to valuation under Section 4A of the Central Excise Act, not Section 4. The bulk sale to soft drink manufacturers did not change the valuation method because the statutory scheme applies to specified goods cleared with declared retail price. The Tribunal also relied on binding Supreme Court precedent on the assessee's own similar transactions, leaving no basis for a fresh merits-based departure. Accordingly, the Section 4A valuation position was confirmed and the Revenue's challenge did not succeed.

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Issues: Whether refrigerators sold in bulk to soft drink manufacturers were required to be valued under Section 4 or Section 4A of the Central Excise Act, 1944.

Analysis: The goods were cleared as packed refrigerators declaring MRP, and duty had been discharged under the MRP-based valuation scheme. The valuation controversy was governed by the statutory distinction between transaction value under Section 4 and deemed valuation under Section 4A for specified goods. The Tribunal noted that the same issue had already been settled in the assessee's own case by the Supreme Court, which had declined to take a different view on refrigerators sold to bottling companies under similar arrangements. In view of that binding precedent, no fresh adjudication on merits was required.

Conclusion: The goods were correctly assessable under Section 4A, not Section 4, and the Revenue's challenge failed.

Ratio Decidendi: Where specified goods are cleared in packaged form with MRP declaration, valuation is governed by Section 4A notwithstanding bulk sale to an institutional buyer, and the matter follows binding precedent on identical facts.

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