Fruit juice based drink classification prevails over lemonade label where product requirements and binding larger bench reasoning are satisfied.

CESTAT Chennai held that the beverage was correctly classifiable under Chapter Sub-heading 2202 9020 as a fruit juice based drink, because the product met the relevant requirements for lime or lemon juice content and total soluble solids. The classification issue had already been settled by a Larger Bench in the appellant's own case, and that binding reasoning could not be displaced by describing the product as lemonade. A change in nomenclature or market description did not justify reclassification under Chapter Sub-heading 2202 1020.

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Issues: Whether the product "Nimbooz" manufactured by the appellant was classifiable under Chapter Sub-heading 2202 9020 as a fruit juice based drink, or under Chapter Sub-heading 2202 1020 as lemonade.

Analysis: The classification issue had already been decided by a Larger Bench in the appellant's own case. The reasoning accepted there was that products having the requisite lime or lemon juice content and total soluble solids satisfy the relevant regulatory requirements and fall within the category of fruit juice based drinks. Applying that determination, the product was not to be treated as lemonade merely because lemon or lime juice was used as flavouring. The declaration of classification under Chapter Sub-heading 2202 9020 was therefore correct and the contrary reclassification could not stand.

Conclusion: The product was correctly classifiable under Chapter Sub-heading 2202 9020 and not under Chapter Sub-heading 2202 1020.

Ratio Decidendi: Where a beverage satisfies the relevant product requirements for fruit juice based drinks and the issue has been substantively settled by binding larger bench reasoning, it cannot be reclassified as lemonade on a mere change in nomenclature or market description.

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