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CAAR Rejects Advance Ruling Application as Classification of Roasted Areca Nuts Was Already Decided by Court

Case Law Details

TaxGuru Citation
2026 taxguru.in 5200
Case Name
In re Madvic Agro India Private Limited (CAAR Mumbai)
Date of Judgement/Order
Only available for paid members
Courts
CAAR
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In re Madvic Agro India Private Limited (CAAR Mumbai)

The Customs Authority for Advance Ruling (CAAR), Mumbai considered an application filed by M/s. Madvic Agro India Private Limited seeking an advance ruling on the classification of “Roasted Areca Nuts (Whole & Cut)” under the Customs Tariff Act, 1975. The application was filed under Section 28-I(1) of the Customs Act, 1962 and was received on 25.02.2026.

The applicant proposed to import roasted areca nuts from Indonesia, Sri Lanka, and Burma. According to the applicant, roasted areca nuts are classifiable under Chapter Heading 2008 and specifically under Tariff Item 2008 1991, which covers roasted nuts. The applicant relied upon the HSN Explanatory Notes and submitted that mere roasting of areca nuts would place the goods under the said tariff classification. The applicant also cited various judicial decisions in support of the contention that HSN Explanatory Notes are dependable guides for classification matters.

The office of CAAR forwarded the application to the jurisdictional Customs Commissionerate at Tuticorin for comments and records. However, no response was received from the Commissionerate.

A personal hearing was conducted on 28.04.2026, during which the applicant’s senior counsel reiterated that the imported goods should be classified under Customs Tariff Heading 2008 1991. Reliance was placed on the decision of the Madras High Court in matters involving classification of roasted areca nuts, including the case of Commissioner of Customs, Chennai-II Commissionerate versus Shahnaz Commodities International Pvt. Ltd. and others, which had also been upheld by the Supreme Court. It was also submitted that the moisture content of the goods would remain below 7%. No representative appeared on behalf of the department during the hearing.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,886

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