Prior Tribunal ruling controls classification of MCPCBs, making the issue no longer res integra and invalidating contrary orders.

Imported Metal Clad Printed Circuit Boards used to manufacture LED lamps were in dispute between tariff item 8534 00 00 and tariff item 9405 99 00. The Tribunal noted that the same classification issue had already been finally decided in the assessee's own case, so the matter was no longer res integra. On that basis, the contrary appellate orders sustaining the department's classification could not be maintained and were set aside. The goods were therefore not classifiable under tariff item 9405 99 00, and the classification challenge succeeded in favour of the appellant.

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Issues: Whether the imported Metal Clad Printed Circuit Boards (MCPCBs) used for manufacturing LED lamps were classifiable under tariff item 8534 00 00 or under tariff item 9405 99 00 of the First Schedule to the Customs Tariff Act, 1975.

Analysis: The classification dispute had already been decided in the appellant's own case by an earlier final order of the Tribunal. In view of that prior determination, the issue was no longer res integra and did not call for fresh debate. The impugned appellate orders sustaining the department's classification could not therefore be maintained.

Conclusion: The goods were held not to be classifiable under tariff item 9405 99 00, and the appellant's classification challenge succeeded.

Final Conclusion: The appellate orders were set aside and the classification dispute was resolved in favour of the appellant on the basis of the earlier Tribunal ruling.

Ratio Decidendi: Where the very same classification issue stands concluded by an earlier final order in the assessee's own case, the matter is no longer res integra and the later contrary order cannot be sustained.

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