Tariff classification settled by binding precedent, so demand, interest and penalty on imported circuit boards could not survive.

Tariff classification of metal clad printed circuit boards used for LED lamp manufacture was the central issue, with the document stating that the goods were to be assessed under the applicable customs tariff entry rather than the alternative heading proposed by the Department. It further records that the classification question had already been settled by binding coordinate Bench precedent on the same product, so the contrary demand confirmation could not be sustained. On that basis, the duty demand, interest and penalty were set aside and the impugned order was annulled in full.

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Issues: Whether the imported goods, being metal clad printed circuit boards used for manufacturing LED lamps, were correctly classifiable under Tariff Item 8534 00 00 of the First Schedule to the Customs Tariff Act, 1975, or under Tariff Item 9405 99 00, and whether the duty demand, interest and penalty confirmed on the importer could be sustained.

Analysis: The dispute turned on tariff classification of the imported goods. The Tribunal noted that the classification issue had already been decided and was no longer open for debate in view of the earlier coordinate Bench decision on the same product. On that basis, the adjudication confirming the demand was held unsustainable.

Conclusion: The classification adopted by the Department was not sustained, and the demand, interest and penalty confirmed against the appellants were set aside.

Final Conclusion: The appeals succeeded and the impugned order was annulled in full.

Ratio Decidendi: Where the tariff classification issue of the imported goods has already been conclusively settled by binding coordinate Bench precedent, the contrary demand confirmation cannot be sustained.

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