Consistency in tariff classification barred a contrary Revenue view where prior classifications had already attained finality.

Earlier accepted tariff classifications for uncoated paperboard, electrical grade insulating pressboard and spacers were treated as binding in the absence of any change in the product description or legal basis. The principle of consistency in classification required the Revenue to follow the classifications already attained finality for the same goods. On that basis, the contrary attempt to classify the products under heading 8546 was not sustainable, and the goods remained classifiable under headings 4805, 4810 and 8547.

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Issues: Whether the products manufactured by the assessee, namely uncoated paperboard, electrical grade insulating pressboard and spacers, were correctly classifiable under headings 4805, 4810 and 8547 of the Central Excise Tariff Act, 1985, and whether the Revenue could take a contrary classification view after earlier classifications had attained finality.

Analysis: The products in dispute were examined separately. The record showed that spacers had earlier been classified under heading 8547 and that order had been accepted by the Revenue. The uncoated paperboard and electrical grade insulating pressboard had also been classified under headings 4805 and 4810 in earlier proceedings, and that classification had attained finality. In these circumstances, and in light of the principle that the Revenue should maintain consistency in classification of the same product, the contrary view taken to classify the goods under heading 8546 could not be sustained.

Conclusion: The products were held to be classifiable under headings 4805, 4810 and 8547, and the Revenue's classification under heading 8546 was rejected.

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