Finality of tariff classification bars contrary customs assessment for identical goods once the appellate view has concluded.

Customs authorities could not reassess identical imported rough forged rings under Tariff Item No. 84.62(3) after an earlier appellate determination had finally classified the same goods under Tariff Item No. 73.15(1). Once that classification attained finality, a subordinate customs officer was bound by the concluded position and could not adopt a contrary view for the same goods. The assessment under Tariff Item No. 84.62(3) was therefore unsustainable, and the petitioners succeeded.

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Issues: Whether the customs authorities could assess the imported rough forged rings under Tariff Item No. 84.62(3) despite an earlier appellate determination that the same goods fell under Tariff Item No. 73.15(1).

Analysis: The earlier appellate orders had already accepted the petitioners' classification of the same goods under Tariff Item No. 73.15(1), and that view had attained finality. In these circumstances, a subordinate customs officer could not adopt a contrary classification for identical goods, and the departmental authorities were bound by the concluded position.

Conclusion: The assessment under Tariff Item No. 84.62(3) was unsustainable and the petitioners succeeded.

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