Final tariff classification governs paper tubes where the same product was earlier accepted under Heading 48.22.

Paper tubes were classified under SH 4822.00 because an earlier appellate classification of the same product under Heading 48.22 had attained finality and been accepted by the Revenue. A contrary classification under SH 4823.90 could not be sustained in the absence of any valid basis, so the prior final classification governed the tariff treatment of the goods.

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Issues: Whether paper tubes manufactured and cleared by the assessee were classifiable under SH No. 4822.00 or under SH No. 4823.90 of the Central Excise Tariff Schedule.

Analysis: The same product had already been classified under Heading 48.22 in an earlier appellate order, and that classification had attained finality as it was accepted by the Revenue. In view of the earlier final classification, the impugned classification under SH No. 4823.90 could not be sustained.

Conclusion: Paper tubes were held classifiable under SH No. 4822.00 and not under SH No. 4823.90.

Ratio Decidendi: Where an earlier classification of the same product under the tariff heading has attained finality and is accepted by the Revenue, a contrary classification of the same goods cannot be sustained without a valid basis.

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