Tariff classification of identical petroleum jelly products followed earlier assessee ruling and confirmed the same classification

Tariff classification of Petroleum Jelly - Aloe Vera and Petroleum Jelly - Baby under CETH 33049990 was upheld after the Tribunal followed its earlier decision in the assessee's own case on the same products for another period. The dispute was limited to classification, and the prior determination on identical goods was treated as controlling support for the same classification. The Tribunal also noted the view that relabelling can amount to manufacture. On that basis, the impugned order was set aside and the assessee obtained relief.

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Issues: Whether Petroleum Jelly - Aloe Vera and Petroleum Jelly - Baby were correctly classifiable under CETH 33049990.

Analysis: The dispute concerned only the tariff classification of the products. The same products had already been considered in the assessee's own case for another period, where the classification under CETH 33049990 was held to be correct. The Tribunal followed that earlier detailed determination and also noted the supporting view that relabelling can amount to manufacture.

Conclusion: The classification under CETH 33049990 was held to be correct and the impugned order was set aside in favour of the assessee.

Final Conclusion: The appeal succeeded and the assessee obtained the resulting relief in law.

Ratio Decidendi: Where an identical product classification issue has already been decided in the assessee's own case, that determination may be followed to uphold the same tariff classification for the disputed goods.

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