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Advance Ruling Application Rejected as Classification Issue Already Decided: CAAR Delhi

Case Law Details

TaxGuru Citation
2026 taxguru.in 8711
Case Name
In re Goyal Industries (CAAR Delhi)
Date of Judgement/Order
Only available for paid members
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In re Goyal Industries (CAAR Delhi)

M/s Goyal Industries, a proprietorship firm holding a valid Importer-Exporter Code, filed an application in Form CAAR-1 before the Customs Authority for Advance Rulings (CAAR), New Delhi, seeking an advance ruling on the correct Customs Tariff classification of imported roasted areca nuts in whole and cut/split forms. The application, received on 22.04.2026 under Section 28H(1) of the Customs Act, 1962, proposed imports from Myanmar, Bangladesh, Thailand, Indonesia, and Burma through ICD Tughlakabad, New Delhi, for subsequent sale in the domestic market. The applicant described the manufacturing process, including de-husking, drying, repeated roasting at temperatures between 130°C and 150°C over two to three days, and cooling cycles, stating that these processes significantly altered the physical and chemical characteristics of the areca nuts.

Upon scrutiny, CAAR observed that the issue raised in the application had already been conclusively decided by the Madras High Court in M/s Shahnaz International Pvt. Ltd. Consequently, the Authority formed a prima facie view that the application was barred under Section 28-I(2)(b) of the Customs Act, 1962, and issued a notice dated 29.04.2026 calling for the applicant’s response.

In reply, the applicant submitted that the facts of its case were similar to those decided by the Madras High Court in Commissioner of Customs, Chennai-II v. Shahnaz Commodities International Pvt. Ltd. The applicant further stated that the Supreme Court, by order dated 25.07.2025, had dismissed Special Leave Petition Nos. 17655-17656/2025, thereby confirming the same issue involved in its application. On this basis, the applicant requested that its advance ruling application be allowed. During the virtual personal hearing held on 17.06.2026, the authorised representative reiterated the submissions made in the application. No authorised representative appeared on behalf of the Department.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,704

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