Seat mechanism components classifiable as parts of seats; binding precedent must be followed on identical goods.

Track assembly, gear vertical adjuster, case sub-assembly, brake sub-assembly and bar seat track lock supplied to car seat manufacturers were treated as integral seat components, with their function being adjustment, movement and locking of the seat assembly. On that basis, the goods were classifiable as parts of seats under CTI 9401 90 00 and not as motor vehicle parts and accessories under CTI 8708 99 00. The note also states that an adjudicating authority must follow a binding earlier decision on identical goods unless it has been set aside by a superior forum, and could not disregard that precedent merely because other rulings were not considered.

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Issues: Whether the imported track assembly, gear vertical adjuster, case sub-assembly, brake sub-assembly and bar seat track lock were classifiable under CTI 9401 90 00 as parts of seats or under CTI 8708 99 00 as parts and accessories of motor vehicles, and whether the adjudicating authority was justified in departing from the binding earlier decision on the same products.

Analysis: The goods were supplied to car seat manufacturers and were used as integral components of complete seats. The track assembly enabled forward and backward movement and adjustment of the seat, the gear vertical adjuster and brake sub-assembly enabled vertical adjustment, and the bar seat track lock secured the seat in the required position. On these facts, the goods had the commercial and functional character of parts of seats and not of standalone motor vehicle accessories. The earlier Tribunal decision in the appellant's own case had held similar child parts to be classifiable under CTI 9401 90 00 and had attained finality. The adjudicating authority was bound to follow that precedent and could not disregard it on the footing that other rulings or advance rulings were not considered. The reliance on the Supreme Court decision dealing with rail assembly and related seat adjuster components was held inapplicable because the goods there were materially different from the present track assembly mechanism supplied to seat manufacturers.

Conclusion: The goods were correctly classifiable under CTI 9401 90 00 as parts of seats, and the contrary classification under CTI 8708 99 00 was unsustainable. The impugned order was liable to be set aside, and the appeal succeeded in favour of the assessee.

Ratio Decidendi: An adjudicating authority must follow a binding precedent on identical goods unless it is set aside by a superior forum, and seat mechanism components supplied to seat manufacturers are classifiable as parts of seats when their essential function is to form an integral part of the seat assembly.

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