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Issues: Whether the imported goods were correctly classifiable under the Customs Tariff and, if so, whether reassessment and consequential refund relief were warranted.
Analysis: The goods had earlier been considered by the Tribunal in connected matters involving the same product. That decision had held the goods classifiable under Heading No. 71.12/15 of the First Schedule to the Customs Tariff Act, 1975. No fresh material was placed to justify departure from that view, and the same classification was applied to the present goods. The Tribunal therefore directed reassessment on that basis, with consequential relief to follow from the reassessment.
Conclusion: The goods were held classifiable under Heading No. 71.12/15, and the matter was directed to be reassessed accordingly with consequential relief in favour of the assessee.
Final Conclusion: The classification dispute was resolved in favour of the assessee, and the duty assessment was ordered to be redone on the basis of the correct tariff heading.
Ratio Decidendi: Where the same goods have already been classified by the Tribunal on full consideration of the tariff scheme, and no fresh material is shown, consistency requires adoption of the earlier classification for the subsequent case as well.