Tariff classification for seats under Heading 48 governed exemption entitlement, so revised reclassification could not reduce the benefit.

Bus seats, railway seats, cavity seats and cinema seats were treated as classifiable under Tariff Heading 48 rather than Chapter Heading 94 for small-scale exemption purposes. The Tribunal followed its earlier precedent on classification, and on that basis held there was no basis to disturb the original assessment or reduce the exemption benefit by reclassifying the goods. The revised classification was rejected, and the exemption entitlement was restored in full, with consequential relief granted to the appellants.

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Issues: Whether bus seats, railway seats, cavity seats and cinema seats were correctly classifiable under Tariff Heading 48 rather than Chapter Heading 94 for the purpose of small-scale exemption under Notification No. 175/86, and whether the exemption benefit could be scaled down on the revised classification.

Analysis: The Tribunal relied on its earlier decision holding that such items were classifiable under Tariff Heading 48. On that basis, there was no justification to alter the original classification adopted by the appellants or to reduce the exemption benefit flowing from the two headings under which their products were assessed.

Conclusion: The revised classification was rejected and the exemption entitlement was restored in full.

Final Conclusion: The appeals succeeded and the impugned orders were set aside, with consequential relief to the appellants.

Ratio Decidendi: Where the applicable tariff classification of goods is already governed by a binding precedent, the exemption consequence must follow the correct classification and cannot be reduced by an inconsistent reclassification.

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