In re Sanmuga International (CAAR Mumbai)
An application for advance ruling was filed by M/s. Sanmuga International 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 a ruling on the tariff classification of “Roasted Areca Nuts (Cut/Whole)” under the First Schedule of the Customs Tariff Act, 1975.
The applicant stated that it intended to import roasted areca nuts, both whole and cut, from Burma, Indonesia, and Sri Lanka. According to the applicant, under the classification framework of the Customs Tariff Act, 1975 as amended by the Finance Bill, 2025, fruits, nuts, and other edible parts of plants fall under Chapter Heading 2008. The applicant contended that roasted areca nuts should be classified under tariff item 2008 19 91 as “other roasted nuts and seeds.” The applicant argued that roasting alters the product and places it within this tariff item, as reflected in the Harmonized System of Nomenclature (HSN) Explanatory Notes.
In support of this position, the applicant cited several Supreme Court decisions, including 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). The applicant submitted that these judgments recognize the HSN Explanatory Notes as a reliable guide for classification of goods.
