Tariff classification can be reopened on a change in legal position, with HSN notes and base-metal predominance guiding classification.

Classification under the Central Excise Tariff may be revisited where the legal position changes, and HSN notes remain a relevant aid to interpretation. Earlier classification approval is not conclusive; it is a relevant factor that cannot be disregarded unless facts, law, or tariff position have changed. For goods composed of more than one metal, Section Note 5 to Section XV requires classification by the base metal predominating by weight. On the facts discussed, the later reclassification was supported by the prevailing legal position, and the prior approval did not prevent the demand.

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Issues: Whether the department could reclassify the goods and sustain the duty demand despite earlier classification approval, in the absence of any change in facts, and whether the goods were classifiable on the basis of the relevant tariff notes and HSN guidance.

Analysis: The classification could be revisited where there was a change in the legal position, and the HSN notes were a relevant aid to classification under the Central Excise Tariff. The earlier approval was not conclusive, but it remained a relevant fact and could not be ignored unless there was a change in facts, law, or tariff position. The Tribunal also applied the rule that where an article is composed of more than one metal, Section Note 5 to Section XV requires classification by the base metal predominating by weight. On the facts found, the later reclassification was supported by the legal position then prevailing and the appellants had not shown any material to displace that conclusion.

Conclusion: The reclassification and consequential demand were upheld, and the appeal failed.

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