Tariff reclassification of imported goods fails where the original assessment is unchallenged and key import documents are missing.

Revenue could not seek reclassification of imported goods at the appellate stage where the original tariff assessment of the Bill of Entry had not been challenged and the basic supporting records were not produced. The classification dispute depended on the assessment record, but the bill of entry, catalogue and literature were not placed on record, and the lower proceedings had proceeded on a different basis. In the absence of a challenge to the original assessment and without material supporting the proposed reclassification, the attempt to alter the classification was not maintainable on merits and was rejected.

---

---

Issues: Whether the revenue could seek reclassification of the imported goods when the original assessment had not been challenged and the relevant basic documents were not produced.

Analysis: The appeal concerned the tariff classification adopted at the time of assessment of the Bill of Entry. The revenue did not produce the bill of entry, catalogue, or literature, and the original classification was never challenged by way of appeal against the assessment. The dispute raised before the lower authority had proceeded on a different basis, and the revenue's attempt to alter the classification at the appellate stage lacked supporting material.

Conclusion: The appeal was not maintainable on merits and was rejected.

---