Retrospective classification lists cannot unsettle an approved classification for an earlier period, while limitation may still be satisfied.

An appeal was held to be within time, so the limitation objection against the appellant failed. However, a revised classification list could not be applied retrospectively to disturb an already approved classification list for the earlier period. The approved classification continued to govern past periods, and the request for retrospective effect was rejected. Despite the limitation finding in favour of the appellant, the challenge failed on merits because retrospective displacement of the existing classification was not permitted.

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Issues: (i) whether the appeal before the appellate authority was filed within time; (ii) whether a revised classification list could be given retrospective effect after an approved classification list had already been in force.

Issue (i): whether the appeal before the appellate authority was filed within time.

Analysis: The appeal was found to have been presented within the prescribed time, and the contrary view taken by the appellate authority was held to be unsustainable.

Conclusion: The limitation objection was rejected in favour of the appellant.

Issue (ii): whether a revised classification list could be given retrospective effect after an approved classification list had already been in force.

Analysis: The goods had already been covered by an approved classification list. The revised classification list filed later could not be applied retrospectively from the earlier date, as the approved classification could not be displaced for the past period in the manner sought.

Conclusion: The request for retrospective effect was rejected and the classification continued to operate as already approved.

Final Conclusion: The appeal failed on merits despite the finding that the limitation objection was not sustainable, and the order resulted in rejection of the challenge.

Ratio Decidendi: A revised classification list cannot be given retrospective effect to unsettle an already approved classification for the earlier period.

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