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Issues: Whether the Superintendent's approval of the classification list could be treated as an adjudication of the classification dispute so as to permit an appeal under the statutory provisions governing departmental appeals.
Analysis: The approval granted by the Superintendent was held to be within a limited delegated function under the classification-list procedure and not a conscious adjudication of the tariff classification on merits. The proper authority for altering the classification remained the Assistant Commissioner. Since the Superintendent had no authority to determine the classification in the manner suggested, the approval of the list could not be equated with an adjudicatory order. The objection was also treated as one of jurisdiction, which could not be dismissed as merely technical.
Conclusion: The approval did not amount to an adjudicating order, and the departmental challenge was not maintainable on that basis.
Final Conclusion: The application was rejected and the Commissioner (Appeals)' view was left undisturbed.
Ratio Decidendi: A delegated administrative approval of a classification list, given by an without authority to decide tariff classification on merits, does not constitute an adjudication amenable to appeal under the departmental appellate provisions.