Final product classification cannot be reopened on unchanged facts; consequential detention based on reclassification also falls.

Where a product classification has already been finally by the appellate authority on the same facts and unchanged tariff provisions, the Department cannot reopen that settled position through a fresh show cause notice or rely on later budget instructions to override the tariff notes; the reclassification notice was therefore without jurisdiction and liable to be quashed. The detention order issued solely in aid of that proposed reclassification also could not survive once the foundational reopening failed, and was likewise quashed. The attempted reassessment was barred by final adjudication, with relief granted to the assessee.

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Issues: (i) Whether the Department could reopen the earlier final classification of the petitioner's product and issue a show cause notice for reclassification under the excise tariff; (ii) Whether the detention order issued in aid of the proposed reclassification was sustainable.

Issue (i): Whether the Department could reopen the earlier final classification of the petitioner's product and issue a show cause notice for reclassification under the excise tariff.

Analysis: The product had already been classified by the appellate authority on the same facts, and there was no change either in the factual position or in the governing tariff provisions. The relevant chapter and section notes required classification of mixed textile products by applying the statutory classification criteria, and the earlier appellate determination had become final. In these circumstances, the Department could not treat later budget instructions as overriding the tariff notes or use them to reopen a settled classification. A fresh notice seeking to disturb that final adjudication was therefore beyond jurisdiction.

Conclusion: The show cause notice for reclassification was without jurisdiction and liable to be quashed, in favour of the assessee.

Issue (ii): Whether the detention order issued in aid of the proposed reclassification was sustainable.

Analysis: The detention order rested on the same unsustainable attempt to reopen the concluded classification dispute. Once the foundation for reassessment and reclassification failed, the consequential detention could not survive independently.

Conclusion: The detention order was unsustainable and liable to be quashed, in favour of the assessee.

Final Conclusion: The writ petitions succeeded, the attempted reclassification was barred by the final earlier adjudication, and the consequential detention action could not stand.

Ratio Decidendi: Where the factual position and governing tariff provisions remain unchanged, the Department cannot reopen a final classification adjudication by issuing a fresh show cause notice, and consequential coercive action based on that reopening also fails.

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