Consistency in tariff classification required connecting rods for air compressors to remain under sub-heading 8414.99.

Connecting rods used in air compressors were classified under sub-heading 8414.99 rather than Heading 84.83. The tariff entry had remained unchanged, and the Department had accepted the same product under sub-heading 8414.99 in later assessments and appellate orders. On that basis, the earlier contrary classification could not be sustained, and consistency in classification required the same treatment for the earlier period. The impugned order was set aside to that extent, with relief granted to the assessee.

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Issues: Classification of connecting rods used in air compressors under the appropriate Central Excise Tariff entry.

Analysis: The dispute concerned whether the goods were classifiable under sub-heading 8414.99 or under Heading 84.83. The classification had already been accepted by the Department under sub-heading 8414.99 in later assessments and appellate orders, and there was no change in the relevant tariff entry. In these circumstances, the earlier contrary classification could not be sustained.

Conclusion: The connecting rods were held classifiable under sub-heading 8414.99 and not under Heading 84.83. The impugned order was set aside to that extent and relief was granted to the assessee.

Ratio Decidendi: Where the Department has ed the same product under a particular tariff sub-heading and the relevant tariff entry remains unchanged, consistency in classification requires that the same classification be applied for the earlier period.

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