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    <title>1981 (11) TMI 59 - HIGH COURT OF JUDICATURE AT BOMBAY</title>
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    <description>An unchallenged appellate classification order attaining finality binds the department unless there is a material change in facts, the manufacturing process, the tariff entry, or the relevant legal position. On the same product and unchanged legal framework, the departmental authority could not reopen classification or refuse refund by treating the earlier appellate order as limited to an earlier period. The earlier finding that waterproof drawing ink was non-excisable therefore continued to govern, and the refusal to grant refund was inconsistent with that binding classification. The impugned order was quashed and the refund claim was allowed.</description>
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      <description>An unchallenged appellate classification order attaining finality binds the department unless there is a material change in facts, the manufacturing process, the tariff entry, or the relevant legal position. On the same product and unchanged legal framework, the departmental authority could not reopen classification or refuse refund by treating the earlier appellate order as limited to an earlier period. The earlier finding that waterproof drawing ink was non-excisable therefore continued to govern, and the refusal to grant refund was inconsistent with that binding classification. The impugned order was quashed and the refund claim was allowed.</description>
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