Tobacco classification dispute resolved by applying tariff parity and limited writ review principles to identical manufacturing process.

Classification of processed tobacco goods turned on whether the finished product fell under CETH 2401 20 90 or CETH 2403 99 10. The article notes that the manufacturing process involved drying, stemming, curing with jaggery-water, cutting, and packing tobacco leaves, and that the same product and process had already been considered in a connected matter. It also explains that advance rulings on classification are binding on the applicant and officer under the GST scheme, while writ review under Articles 226 and 227 is limited to jurisdictional error, illegality, natural justice breach, or perversity. On that basis, parity with the earlier view was required and the classification under CETH 2401 20 90 was treated as the legally sustainable entry.

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Issues: Whether the goods manufactured by the assessee were classifiable under CETH 2401 20 90 or under CETH 2403 99 10, and whether the impugned advance ruling and appellate order could be interfered with in writ jurisdiction.

Analysis: The goods were produced by purchasing raw dried tobacco leaves, removing stems and dust, curing the leaves with jaggery-water, cutting them into small pieces, and packing them for sale. The dispute concerned the correct tariff classification of the finished product. The statutory scheme in Chapter XVII of the Central Goods and Services Tax Act, 2017 permits advance ruling on classification questions, and Section 103(1) makes such ruling binding on the applicant and the concerned officer. Judicial review under Articles 226 and 227 remains available, but its scope is limited to jurisdictional error, illegality, breach of natural justice, perversity, or similar defects and is not appellate in nature. The same product and process had already been considered in a connected matter, and parity of treatment was necessary to avoid unequal tax consequences for similarly placed persons.

Conclusion: The goods were held to fall under CETH 2401 20 90, and the advance ruling and appellate order were set aside in writ jurisdiction.

Final Conclusion: The assessee succeeded, and the classification adopted by the authorities could not stand in view of the binding earlier view on the same product and process.

Ratio Decidendi: Where the manufacturing process and product are identical to a previously accepted case, and the statutory scheme of advance ruling is subject to limited judicial review, the classification must conform to the legally sustainable tariff entry and cannot be upheld if it produces unequal treatment among similarly placed assessees.

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