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CAAR Advance Ruling Application Rejected as Classification Issue Already Decided by Court

Case Law Details

TaxGuru Citation
2026 taxguru.in 2936
Case Name
In re M G Trade Links (CAAR Mumbai)
Date of Judgement/Order
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In re M G Trade Links (CAAR Mumbai)

The application for advance ruling was filed by M/s. M G Trade Links before the Customs Authority for Advance Ruling (CAAR), Mumbai, under Section 28H(1) of the Customs Act, 1962. The application, received on 7 January 2026, sought clarification regarding the tariff classification of “Roasted Areca Nuts (Cut/Whole)” under the First Schedule of the Customs Tariff Act, 1975.

The applicant stated that it intends to import roasted areca nuts, both whole and cut, from Burma, Indonesia, and Sri Lanka. According to the applicant, under the classification scheme of the Customs Tariff Act, 1975, as amended by the Finance Bill, 2025, fruits, nuts, and other edible plant parts fall under Chapter Heading 2008. The applicant contended that roasted areca nuts are specifically classifiable under tariff item 2008 19 91 as “other roasted nuts and seeds.” The applicant argued that the product becomes classifiable under this tariff item due to the roasting process and relied on the Harmonized System of Nomenclature (HSN) Explanatory Notes, which mention roasted nuts under this classification.

To support its argument, the applicant cited several Supreme Court decisions which held that HSN Explanatory Notes serve as a reliable guide for classification matters. The judgments referred to included decisions in L.M.L. Ltd. v. Commissioner of Customs (2010), Holostick India Ltd. v. Commissioner of Central Excise, Noida (2015), and Collector of Central Excise, Shillong v. Wood Craft Products Ltd. (1995).

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Author Info

CA Sandeep Kanoi
Qualification: Graduate, CA in Job / Business, DD
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 22,576

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