Approved classification list denial binds assessee; RT-12 finalisation can enforce duty liability without section 11A limitation.

An approved classification list that expressly denies a concession binds the assessee unless it is challenged in appeal, and RT-12 finalisation may be used as a statutory verification of duty paid with reference to the approved price and classification lists rather than a fresh adjudication of entitlement. On that basis, the assessee could not lawfully claim the denied concession in its PLA, and the limitation rule under section 11A was held inapplicable to the RT-12 finalisation process. The demand raised on finalisation was therefore upheld and the lower appellate view was reversed.

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Issues: Whether the respondents could continue to avail the benefit of a concession that had been expressly denied in the approved classification list, and whether limitation under section 11A applied to the RT-12 finalisation proceedings.

Analysis: The denial of the concession in the classification list had not been challenged by the respondents in appeal, and they were therefore bound by the approval as granted. RT-12 finalisation was treated as a statutory verification of duty paid with reference to the approved price list and classification list, and not as a fresh adjudication of entitlement to the concession. In that setting, the respondents could not lawfully take credit for the denied concession in their PLA, and the limitation provision under section 11A was held to have no relevance on the facts.

Conclusion: The demand raised on RT-12 finalisation was upheld and the objection based on limitation was rejected.

Final Conclusion: The appeal succeeded, the order of the lower appellate authority was set aside, and the departmental demand stood restored.

Ratio Decidendi: Where a concession is expressly denied in the approved classification list and is not challenged, RT-12 finalisation may enforce the approved duty liability as an arithmetical verification, and limitation under section 11A does not govern that process.

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