Binding tariff classification controls later identical disputes over beverage classification and defeats a contrary revenue demand.

Tariff classification of beverages was determined by reference to an earlier Larger Bench ruling holding that the goods fell under Chapter Heading 22029020 as fruit pulp or fruit juice based drinks, not under Chapter Heading 22021020 as lemonade. That binding classification was also followed in the appellant's earlier proceedings, and the contrary view adopted by the Revenue could not be sustained on identical facts. The text states that the appellant's classification was accepted, the demand was set aside, and the appeal succeeded. The stated principle is that an authoritative Larger Bench classification governs later disputes involving the same product unless distinguishable facts are shown.

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Issues: Whether the beverages manufactured by the appellant were correctly classifiable under Chapter Heading 22029020 of the First Schedule to the Central Excise Tariff Act, 1985 as fruit pulp or fruit juice based drinks, or under Chapter Heading 22021020 as lemonade, and whether the demand founded on the contrary classification could be sustained.

Analysis: The dispute turned on tariff classification of the products. A prior Larger Bench ruling had held that the goods in question fall under tariff item 22029020 as fruit pulp or fruit juice based drinks. The same view had also been followed in the appellant's own earlier proceedings. In light of that binding classification position, the contrary view taken by the Revenue could not be sustained.

Conclusion: The classification adopted by the appellant was held to be correct, the demand was set aside, and the appeal succeeded.

Ratio Decidendi: Where a Larger Bench has authoritatively classified a product under a particular tariff item, that classification governs subsequent identical disputes unless distinguishable facts are shown.

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