Refractory ceramic goods classification follows binding precedent where functionally identical products serve the same industrial purpose.

Refractory ceramic sleeves and B.P. sets used for pouring molten metal in steel plants were classified under Chapter Heading 69.01, not Sub-heading 6911.00. The classification issue was resolved by applying an earlier three-Member Bench precedent that had already placed refractory sleeves under Chapter Heading 69.01. Because the two products were of the same nature and served the same industrial purpose, the same reasoning was extended to both goods, and the contrary departmental classification was set aside.

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Issues: Whether refractory Sleeves and B.P. Sets were classifiable under Chapter Heading 69.01 or under Sub-heading 6911.00.

Analysis: The products were refractory ceramic materials used for pouring molten metal in steel plants. The classification question was governed by an earlier three-Member Bench decision holding that refractory Sleeves fall under Chapter Heading 69.01. As Sleeves and B.P. Sets were of the same nature and used for the same purpose, the earlier decision was applied equally to both products.

Conclusion: The goods were classifiable under Chapter Heading 69.01 and not under Sub-heading 6911.00. The classification adopted in the impugned order was set aside, and the appeal succeeded.

Final Conclusion: The correct tariff classification was held in favour of the assessee, resulting in reversal of the departmental classification order.

Ratio Decidendi: Refractory ceramic goods used for the same industrial purpose are to be classified in accordance with the binding precedent applicable to that product category, and the same reasoning extends to functionally identical goods.

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