Settled excise classification supports SSI exemption for air-conditioning and refrigeration parts, with Revenue unable to depart from prior rulings.

Parts and accessories manufactured and cleared as components of air-conditioning and refrigeration machinery were treated as correctly classified for excise purposes, and the settled classification was followed for SSI exemption under Notification No. 175/86-CE. The Tribunal relied on the appellant's earlier classification being upheld in its own case, supported by Trade Notice No. 78/86 and Board Circular No. 6/96-CX.IV. As the Revenue had no basis to depart from that settled position, the classification dispute was resolved in favour of the appellant and the goods were held entitled to the claimed SSI exemption.

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Issues: Whether the parts and accessories manufactured and cleared by the appellant, as parts of air-conditioning and refrigeration machinery, were correctly classified and entitled to the benefit of SSI exemption under Notification No. 175/86-CE dated 01.03.1986.

Analysis: The appellant's classification of the goods had already been upheld in its own case by the Commissioner (Appeals) and thereafter by the Tribunal. That earlier view was based on Trade Notice No. 78/86 dated 24.10.1986 and Board's Circular No. 6/96-CX.IV, both of which supported the classification adopted by the authorities. The Tribunal held that the Revenue could not depart from that settled position, and there was no reason to take a different view in the present appeal.

Conclusion: The classification dispute was decided in favour of the appellant, and the goods were entitled to the claimed SSI exemption.

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