Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
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Geomembranes manufactured through a woven fabric stage followed by lamination were held classifiable under Chapter 59, specifically HSN 5911, rather than as plastic goods under Chapter 39. The Appellate Authority applied the binding jurisdictional precedent of the Gujarat High Court in an identical product dispute and treated that ruling as final. It rejected the Department's reliance on contrary case law, noting that the cited authority did not address woven fabric as a textile product and was therefore inapposite. On that basis, the advance ruling classifying geomembranes under HSN 5911 was upheld and the departmental appeal was dismissed.
Geomembranes manufactured through a woven fabric stage followed by lamination were held classifiable under Chapter 59, specifically HSN 5911, rather than as plastic goods under Chapter 39. The Appellate Authority applied the binding jurisdictional precedent of the Gujarat High Court in an identical product dispute and treated that ruling as final. It rejected the Department's reliance on contrary case law, noting that the cited authority did not address woven fabric as a textile product and was therefore inapposite. On that basis, the advance ruling classifying geomembranes under HSN 5911 was upheld and the departmental appeal was dismissed.
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