CAAR Rejects Ruling on Roasted Areca Nut Classification Citing Madras HC Decision

In re AZ Overeas (CAAR Delhi)

M/s AZ Overseas filed applications dated 29.04.2026 and 05.05.2026 before the Customs Authority for Advance Rulings (CAAR), New Delhi under Section 28H of the Customs Act, 1962 seeking an advance ruling on the classification of Oven Roasted Areca Nuts proposed to be imported from ASEAN countries and on the applicability of the customs duty exemption under Sl. No. 172 of Exemption Notification No. 46/2011-Customs dated 01.06.2011. The applicant stated that the imported goods are whole areca nuts subjected only to de-husking, drying, light roasting, cooling, sorting, grading and packing without addition of salt, flavouring agents, sweeteners, lime or spices. The applicant asserted that the goods remain plain roasted areca nuts intended for sale or consumption after cutting or grading.

According to the applicant, the competing tariff classifications were Chapter Heading 0802 and Tariff Item 2008 19 20. The applicant submitted that Chapter 8 covers fresh or dried nuts and the processes specified therein include drying but not roasting. It argued that roasting is distinct from drying, produces physical and chemical changes, and therefore roasted areca nuts do not fall under Chapter 8. The applicant further contended that roasted areca nuts are commercially understood as roasted betel nuts, that Chapter 20 specifically covers preparations of nuts, and that Tariff Item 2008 19 20 specifically enumerates areca nuts. The applicant also relied upon Rule 3(a) of the General Rules for Interpretation, Chapter Notes, HS Explanatory Notes, common trade understanding and several judicial decisions and advance rulings in support of classification under Tariff Item 2008 19 20. On that basis, it claimed eligibility for exemption under Sl. No. 172 of Notification No. 46/2011-Customs.

Upon scrutiny, CAAR observed that the issue appeared to have already been conclusively decided by the Madras High Court in the case of M/s Shahnaz Commodities International Pvt. Ltd. Consequently, a notice dated 21.05.2026 was issued to the applicant. In response, the applicant reiterated that the Madras High Court had held that imported roasted areca nut is classifiable under Chapter Heading 2008, specifically under sub-heading 2008 19 20, and again requested an advance ruling holding that the imported roasted areca nuts were classifiable under that tariff entry and eligible for the claimed exemption. A personal hearing was held on 25.06.2026, where the authorised representative reiterated the submissions already made.

Before examining the merits, the Authority considered the maintainability of the application. Referring to Section 28-I(2) of the Customs Act, 1962, it noted that an application cannot be allowed where the question raised is already pending in the applicant’s case before any customs authority, the Appellate Tribunal or any Court, or where the same question has already been decided by the Appellate Tribunal or any Court. The Authority observed that the advance ruling mechanism is intended to provide certainty and reduce litigation and that subordinate authorities are bound by judicial precedents. It also referred to the Supreme Court decision in Union of India v. Kamlakshi Finance Corporation Ltd., 1991 (55) ELT 433 (SC), regarding the binding nature of higher judicial precedents.

CAAR found that the question raised in the applications was squarely covered by the judgment of the Madras High Court in M/s Shahnaz International Pvt. Ltd. [2023 (386) E.L.T. 214 (Mad.)], where the classification of roasted areca nuts had already been examined and decided. Although the applicant had also sought a ruling on the availability of the customs duty exemption under Sl. No. 172 of Notification No. 46/2011-Customs, the Authority observed that this question had not been covered in the Madras High Court judgment. However, it held that the statutory framework governing advance rulings neither contemplates nor permits partial rejection of an application and requires the application to be admitted or rejected in its entirety on the prescribed statutory grounds.

Accordingly, the Authority held that, in view of the Madras High Court judgment and the principles of judicial discipline and binding precedent, it would refrain from pronouncing any ruling on the classification issue. Since partial rejection of an advance ruling application was not envisaged under the statutory scheme, the Authority rejected the application in its entirety. The application was not allowed and was disposed of accordingly.

FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, DELHI

M/s AZ Overseas, 9/2121, Ground Floor, Gall No. 8, Kailash Nagar, Gandhi Nagar, Delhi – 100031 (herein referred to as “applicant”), having IEC No. ACJFA48451_, submitted applications dated 29.04.2026 and 05.05.2026 respectively before the Customs Authority for Advance Rulings, New Delhi (CHAR, New Delhi in short) For obtaining Advance Ruling under Section 28H of the Customs Act, 1962, to seek clarity on the classification on the import of ‘Oven Roasted Areca Nuts’ to India. The application was accordingly registered under Serial No. 18/2026-27 dated 29.04.2026 and 22/2026-27 dated 05.05.2026.

STATEMENT OF RELEVANT FACTS HAVING A HEARING ON THE QUESTION (S) ON WHICH ADVANCE RULING IS REQUIRED

1.1 The Applicant is engaged in the business of import and trading of Areca Nut (Betel Nut) and proposes to import Roasted Areca Nut from ASEAN countries, including Indonesia, Myanmar, Vietnam, and Thailand.

1.2 The proposed goods arc whole areca nuts, which undergo the following processes in the country of export:

> De-husking

> Drying

> Light roasting without addition of salt, Flavouring agents, sweeteners, lime, or spices

1.3 The roasting process is undertaken solely to reduce moisture content, enhance shelf life, and prevent fungal infestation, and does not alter the essential character of the areca nut as an edible nut.

1.4 PROCESS FLOW CHART

(To pre-empt objections on “mere drying” vs. true roasting)

RAW ARECA NM’ (Harvested)

↓

De-husking/ Cleaning

↓

Pre-Drying/Sun-Drying

↓

HIGH-HEAT ROASTING (= 30-150°C or per supplier protocols)

↓

COOLING & MOISTURE REDUCTION (below industry target, e.g., <6%)

↓

SORTING / GRADING

↓

PACKING for export

1. 5 The imported goods are:

> Not sweetened

> Not flavoured

> Not mixed with tobacco or lime

> Not prepared as pan masala or supari mixtures

1.6 The goods remain plain roasted areca nuts, intended for further sale or consumption after cutting/grading.

1.7 DESCRIPTION OF GOODS

• Product Name: Roasted Areca Nut (Betel Nut)
• Form: Whole
• Processing: Drying and light roasting only
• Additives: Nil
• End Use: Chewing / further processing
• Country of Origin: ASEAN Countries

1.8 ASEAN FTA & RULES OF ORIGIN (Roasted Areca Nut)

1) ASEAN-India Trade in Goods Agreement (AITIGA)

Under the ASEAN-India FTA (AITIGA), goods traded between India and ASEAN countries may benefit from preferential duty if originating criteria are fulfilled:

• Basic Principles:

√ Agricultural products produced or substantially transformed in ASEAN signatory territories are treated as originating if they satisfy the FTA’s specific Rules of Origin (ROO).

√ ROO generally apply either tariff shift or value-added tests depending on product classification. For processed agricultural items like roasted nuts:

• If the processing (e.g., roasting) amount to a tariff shift (resulting in a new HS subheading), and
• If ASEAN origin content meets ROO thresholds,
• then the goods can qualify as originating goods for preferential treatment. (Standard FTA ROO practice; see general rules under many FTAs for processed agricultural goods.)

1.9 QUESTION ON WHICH ADVANCE RULING IS SOUGHT

(i) Whether Oven Roasted Areca Nut, imported from ASEAN countries and subjected only to drying and roasting without addition of any ingredients, is classifiable under Customs Tariff Heading 2008 19 20?

(ii) In case the said item i.e. Oven Roasted Areca Nut merits to be classified under Tariff Item No. 2008 19 20, whether exemption from Duty of Customs as provided under Sl.No. 172 of the Exemption Notification No. 46/2011-Cus Dated 1.6.2011 would apply to the goods under question?

APPLICANT’S INTERPRETATION OF LAW

1.10 For the item under question i.e. Oven Roasted Areca Nut, there are two competing classification namely (i) Chapter 8, Heading 0802 and Tariff Item No. 0802 80 10 and (ii) Chapter 29, 008, Sub-heading 2008 19 and Tariff Item No. 2008 19 20. The applicability of these two Tariff item nos are examined in the following paras.

1.11 Chapter 8 of the Customs Tariff covers fruits, nuts arid peel of citrus fruits or melons (including watermelons) generally intended for human consumption (whether as presented or after processing). As per explanatory Notes to HS, these goods may be fresh (including chilled), frozen (whether or not previously cooked by steaming or boiling in water or containing added sweetening material) or dried (including dehydrated, evaporated or freeze-dried): provided they are unsuitable for immediate consumption in that state, they may be provisionally preserved (e.g. by Sulphur dioxide gas, in brine, in Sulphur water or in other preservative solutions). The note specifies the physical status of the goods along with corresponding processes that could be carried on those goods under this chapter. Note 3 to Chapter 8 further states that Dried fruits or dried nuts of this Chapter may be partially rehydrated or treated for the following purposes:

a) For additional preservation or Stabilisation (for example, by moderate heat treatment, sulphating, the addition of sorbic acid or potassium sorbate);

b) To improve or maintain their appearance (for example, by the addition of vegetable oil or small quantities of glucose syrup), provided that they retain the character of dried fruit or dried nuts.

1.12 The areca/betel nut is mentioned in Heading 0802, specifically under sub-heading 080280. In the WCO Explanatory Note to HS (Fifth Edition (2012)), explanatory note to Heading 0802 states ” This heading also covers areca (betel) nuts used chiefly as a masticatory, cola (kola) nuts used both as masticatory and as a base in the manufacture of beverages and an edible, nutlike, spiny-angled fruit of the species Tarpa natans, sometime referred to as water chestnut”. It may be noted that although one of the main uses of the goods under consideration is masticatory but the process of roasting which the goods under consideration is subjected, has not been referred anywhere in this Explanatory Note.

1.13 The processes mentioned in Chapter 8 include chilling, steaming, boiling, drying and provisionally preserving. It does not specifically include the process of roasting. It is important to understand the difference between the processes of drying and roasting. The terms, however, are not defined in the Customs Tariff Act, 1975. Therefore, these terms have to be understood in a commonly accepted sense. In common trade parlance, “drying” is a method of food preservation by the removal of water. On the other hand, “roasting” means the excess or very high heat treatment that produces fundamental chemical and physical changes in the structure and composition of the goods, bringing about a charred physical appearance. Therefore, drying is a moisture removal process involving methods such as dehydration, evaporation, etc., whereas roasting is a severe heat treatment process. It may be pertinent to note that The Hon’ble Apex Court in the case of Alladi Venkateswarlu vs. Government of Andhra Pradesh reported 1978 AIR 945 held that “the commonly accepted sense of a term should prevail in construing the description of an article of food”.

1.14 Thus, it may be seen that roasted Areca Betel Nut is different from the areca nuts as specified under CTH 080280. The process specified in Chapter 3 does not cover roasting process.

1.15 Without prejudice to the above, the Applicant submits that it would not be out of place to mention that in the market, the impugned product is traded as ‘roasted betel nuts. In the case of G.S. Auto International Ltd. vs. Collector of C. Ex. Chandigarh 2003 (152) ELT 3(SC), the Hon’ble Supreme Court held that this issue was no longer res intaglio, as this Court had held earlier that the true test for classification was the test of commercial identity. Thus, it needs to be ascertained as to how the goods in question are referred to in the market by those who deal with them, be it for the purposes of selling, purchasing or otherwise, the Supreme Court held. In this regard, the Supreme Court cited and relied upon its earlier judgments in the cases of Jaishri Engineering Co. (P) Ltd. v. Collector of Central Excise [1989 (40) E.L.T. 214), Purewal Associates Limited v. Collector 1996 (87) E.L.T. 321 (S.C.), and Plasma Machine Mfg. Co. Pvt. Ltd. v. Collector of Central Excise [1991(51) E.L.T.161(S.C.)]

1.16 Further, in the case of United Offsets Process Pvt. Ltd. Vs Assistant Commissioner of Customs [1988(38)ELT 568(SC), it was held that: “If there is no meaning attributed to the expressions used in the particular enacted statute then the items in the customs entries should be judged and analysed on the basis of how these expressions are used in the trade or industry or in the market or, in other words, how these are dealt with by the people who deal in them, provided that there is a market for these types of goods. This principle is well-known as classification on the basis of trade parlance. This is an accepted form of construction- It is a well-known principle that if the definition of a particular expression is not given, it must be understood in its popular or common sense, viz., in the sense how that expression is used every day by those who use or deal with those goods.”

1.17 Therefore, in view of the above discussion and by application of common parlance test, the goods under consideration that is Oven Roasted Areca Nuts’ does not merit classification under Chapter 8 and more specifically Sub-heading 080280.

1.18 Having examined the goods under question does not merit classification under Chapter 8 of the Customs Tariff, the applicant examines possibility of classification of impugned goods under Chapter 20 of the Customs Tariff. Chapter 20 covers the preparation of Nuts. One of the process for preparing the subject goods is specified in Heading 2008 i.e. roasting. Roasting is the essential process for the preparation of impugned goods. The subject goods are not excluded by any chapter note or explanatory note from Heading 2008. Therefore, it is evident that the subject goods are classifiable under Heading 2008 based on the terms of the Heading 2008 and Notes to Chapter 20.

1.19 Without prejudice to above, it is also submitted that Chapter 20 of the Tariff covers the Preparations of vegetables, fruit, nuts or other parts of plants. As per Chapter Note 1 (a) to Chapter 20, the Chapter does not cover vegetables, fruits or nuts prepared or preserved by the processes specified in Chapter 7,8 or 11. Therefore, vegetable, fruit or nut products or preparations made other than by the processes specified in Chapter 7, 8 or 11 are classifiable in Chapter 20. The processes specified in Chapter 7, 8 or 11 mainly include freezing. steaming, boiling, drying, provisionally preserving and milling. Therefore, any vegetable, fruit, nut or edible parts of a plant which is prepared or preserved by any other process than these are liable to be classified under Chapter 20. Heading 2008 covers Fruit, nuts and other edible parts of plants, otherwise prepared or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere specified or included. Roasting is a process used for bringing in to existence roasted nuts and as discussed earlier, it is clear that the process mentioned in Chapter 8 do not cover roasting process.

1.20 Further, As per Rule 3 (a) of the General Rules of Interpretation (GIR) 3(a) of the Customs Tariff Act, 1975, when by application of GIR 2(b) or for any other reason, the goods are, prima facie, classifiable under more than one Heading, the ‘most specific description’ is preferred. When the Chapter/Section notes along with terms of heading and explanatory notes are examined for both Headings 0802 and 2008, it may be seen that roasted betel nuts find a specific description in Heading 2008. Therefore, on the application of GIR 3(b), the subject goods merits classification under Heading 2008 and more specifically under Sub­heading 2008 19 and Tariff Item no 20081920 as “Other roasted nuts and seeds”

1.21 Sub-heading 2008 19 specifically covers “Other nuts”, and tariff item 2008 19 20 specifically enumerates Areca Nut.

1.22 Roasting is a recognized method of preparation/preservation, explicitly contemplated under Chapter 20, and does not take the product outside Heading 2008 so long as:

> No ingredients are added, and

> The product remains an edible nut in its natural identity.

1.23 Chapter 8 (CTH 0802) applies only to raw or dried areca nuts. Once the nut is roasted, it ceases to be classifiable under Chapter 8 and correctly migrates to Chapter 20, as per:

> Chapter Notes

> HS Explanatory Notes

> Common trade understanding

1.24 15. The goods are not classifiable under any heading relating to pan masala, supari preparations, or food preparations, as there is no mixing, flavouring, or compounding.

1.25 16. Therefore, Roasted Areca Nut, being specifically named in the tariff, merits classification under CTH 2008 19 20.

SUPPORTING LEGAL AUTHORITIES (CAAR / CESTAT / HIGH COURT)

1.26 The Hon’ble Allahabad High Court upheld that roasted areca nuts, where the heat treatment is more than simple drying, are correctly classified under CTH 2008 19 20 (other roasted nuts & seeds), not under Chapter 08. The Court distinguished drying (moisture removal) from roasting (severe heat altering physical/chemical properties) and confirmed roasted areca has distinct character and fits Chapter 20.

1.27 In the matter of Rawder Petroleum Pvt. Ltd. v. Union of India, CESTAT upheld classification of roasted areca nuts under 2008 19 20, reasoning repeated roasting cycles at sustained higher temperatures produce a product commercially understood as roasted (not merely dried).

1.28 The Hon’ble Madras High Court affirmed that roasted areca/betel nut merits classification under CTH 2008 19 20, noting roasting is a separate process from drying and the specific tariff entry governs.

1.29 In the matter related to Shree Ganesh Traders, Ld CAAR Mumbai consistently held that plain roasted areca/betel nuts are classifiable in 2008 19 20:

1.30 The above view of the applicant that Oven Roasted Areca Nuts’ is classifiable under Tariff Item no 20081920 is reinforced by the Advance Ruling of Mumbai Customs Authority for Advance Ruling in the case of Shahnaz Commodities International Pvt Ltd I (2023)4 Centax 231 (A.A.R-Cus-Mum). The Authority for Advance Ruling while deciding a n application for advance Ruling ^.filed by the Shahnaz Commodities International Pvt Ltd ruled that ‘Roasted Areca Nuts-whole as well as cut merit classification under Heading 2008 and specifically under sub-heading 2008 19 20 of the First Schedule of the Customs Tariff Act, 1975.

1.31 The above decision of the Authority of Advance Ruling has been affirmed by the High Court of Judicature at Madras [2023(386) ELT 214 (Mad))

1.32 The Authority of Advance Ruling, Delhi in the case of M/s RV International in application no. 66/2024 had ruled that “the Roasted areca/betel nuts fall under Custom Tariff Heading 2008, specifically under CTH 2008 19 20 ‘Other roasted nuts & seeds’ of Chapter 20 of the First Schedule of the Customs Tariff Act, 1975.’

1.33 The Applicant in support of its claim that Roasted areca is classifiable under Tariff Item No 20081920 also relies upon the following Advance Ruling:

• A-One Traders (Ruling No. CAAR/Del/A One/60/2023 (A.A.R-Cus-Delhi))
• M/s TMK Traders [Ruling No CAAR/Mum/ARC/89/Mumbai
• Universal Impex 2023(385) ELT 587 (AAR-Cus-Mum)

1.34 The above discussed Advance Rulings are applicable in the present case also as the impugned goods, namely Oven Roasted Areca Nuts are identical to the products those were under consideration before the Hon’ble Authority for Advance Ruling in the above referred rulings.

1.35 It is submitted that as the Applicant firmly believes that as the Roasted Oven Areca Nut is classifiable under tariff Item No 20081920, The Applicant also believes that benefit of exemption from customs duty as provided under SI. No 172 of exemption Notification No 46/2011-Customs Dated 1.06.2011 would also be applicable to the Applicant on import of Roasted Oven Areca Nut from the ASEAN Countries. It may be seen that S No 172 of exemption Notification No 46/2011-Customs Dated 1.06.2011, exemption from customs duty is extended to all goods classified under sub-headings 2007 10 to 2008 20. Since as per the above interpretation of the Applicant, Roasted Oven Areca Nut is classifiable under tariff Item No 20081920, the Applicant would also be eligible for exemption from duty SI No 172 of exemption Notification No 46/2011-Customs Dated 1.06.2011

1.36 In light of the above said submissions, the impugned goods i.e., Roasted Oven Areca Nut would merit classification under tariff Item No 20081920, and, would be eligible for exemption from payment of BCD as per SI No. 172 of exemption Notification No 46/2011-Customs Dated 01.6.2011.

1.37 DECLARATION UNDER SECTION 28-I OF THE CUSTOMS ACT, 1962

The Applicant hereby declares that:

• The question raised herein is not pending before any Customs authority, Appellate Tribunal, or Court.
• No proceedings, investigation, or show cause notice are pending on the same issue.
• The information furnished in this application is true, complete, and correct.

PRAYER

1.38 In view of the facts and legal submissions made hereinabove, the Applicant most respectfully prays that this Hon’ble Authority may be pleased to:

a) Issue an Advance Ruling holding that Roasted Areca Nut imported from ASEAN countries, without addition of any ingredients, is classifiable under Customs Tariff Heading 2008 19 20; and would be eligible for exemption from payment of BCD SI No. 172 of exemption Notification No 46/2011-Customs Dated 01.6.2011.

b) Pass such other or further orders as may be deemed fit and proper in the interest of justice.

Additional submission by the applicant

2.1 Upon a careful scrutiny of the application, it was observed that the issue arising for consideration therein stands conclusively decided by the Hon’ble Madras High Court in case of M/s Shahnaz Commodities International Pvt. Ltd. [2023 (386) E.L.T 214(Mad.)]. In view of the said binding judicial pronouncement, the present application appeared, prima facie, to be hit by the bar under Section 28-I (2)(b) of the Customs Act, 1962 and are, therefore, liable for rejection. Consequently, a notice dated 21.05.2026 was issued to the applicant calling upon them to submit their response in the matter.

2.2 The additional submission of the applicant was received in this office on 18.06.2026. The same are reproduced hereunder:

It is a matter on record that the Hon’ble High Court of Madras, in the landmark judgment rendered in the case of Commissioner of Customs vs. M/s. Shahnaz Commodities International Pvt. Ltd., has categorically held that imported roasted areca nut/betel nut is classifiable under Chapter Heading 2008, specifically under sub-heading 2008 19 20 of the First Schedule to the Customs Tariff Act, 1975, and not under Chapter 08.

In view of the aforesaid judicial pronouncement, coupled with the admitted commercial processing undertaken on the imported goods, it is, therefore, respectfully submitted that “Roasted Areca Nut” imported from ASEAN Countries merits classification under Customs Tariff Heading 2008 19 20.

In view of the facts and legal submissions, the Applicant once again most respectfully prays that this Hon’ble Authority may be pleased to issue an Advance Ruling holding that Roasted Areca Nut imported from ASEAN countries, without addition of any ingredients, is classifiable under Customs Tariff Heading 2008 19 20; and would be eligible for exemption from payment BCD SI No. 172 of exemption Notification No 46/2011-Customs Dated 01.6.2011 It is further reiterated that the question raised in the present application is not pending for decision before any Customs Authority, Appellate Tribunal, or Court, and that the facts stated herein are true and correct to the best of our knowledge and belief.

3. Personal hearing:

Personal hearing in the said application was held on date 25.06.2026, wherein authorized representative, Mr. Abinash Kr. Sinha attended the same and reiterated the same which were already submitted with the application of the applicant

Discussion and Findings:

4.1 I have gone through the application of advance ruling, additional submission of the applicant and relevant provisions in this regard. As issue of maintainability has to be decided first before proceeding to examine the matter on merit; I decide to examine the matter of maintainability first.

4.2 Before I proceed, I would like to refer to Section 28-I (2) of the Customs Act, 1962, which governs the admissibility of applications before the Custom Authority for Advance Rulings (CAAR). The relevant portions of the provisions of Section 28-I (2) of the Customs Act, 1962 reads as under:

28-I. Procedure on receipt of application: (1) On receipt of an application, the Authority shall cause copy thereof to be forwarded to the [Principal Commissioner of Customs or Commissioner of Customs) and, if necessary, call upon him to _.furnish the relevant records:

Provided that where any records have been called for by the Authority in any case, such records shall, as soon as possible, he returned to the Principal Commissioner of Customs or Commissioner of^. Customs)

(2) The Authority may, after examining the application and the records called for, by order, either allow or reject the application

Provided that the Authority shall not allow the application question raised in the application is, where the

(a) already pending in the applicant’s case before any officer of customs, the Appellate Tribunal or any Court,

(b) the same as in a matter already decided by the Appellate Tribunal or any Court.

4.3 From the above, I find that Section 28-1 (2) of the Customs Act, 1962 governs the admissibility of applications before the Custom Authority for Advance Rulings (CAAR). The first proviso to sub-section (2) stipulates that the Authority shall not allow the application where the question raised in the application is (a) already pending in the applicant’s case before any officer of customs, the Appellate Tribunal or any Court; or (b) the same as in a matter already decided by the Appellate Tribunal or any Court.

4.4 Further, I understand that the entire mechanism of advance rulings is a trade facilitation measure introduced with the aim of reducing litigation and providing certainty to assessees, consistent with Article 3 of the WTO Trade Facilitation Agreement. The WTO framework itself recognizes two distinct situations where advance rulings may be declined: (a) when the issue is pending in the applicant’s own case, and (b) when the issue has already been decided by an appellate tribunal or court. The first is applicant-specific, whereas the second is applicant-agnostic. This distinction is necessary because advance rulings are implemented by Departmental officers who are duty bound to apply the law as settled in their jurisdiction. In India, this position is fortified by the ruling of the Hon’ble Supreme Court in Union of India v. Kamlakshi Finance Corporation Ltd, 1991 (55) ELT 433 (SC), which underscores the binding nature of precedent and the obligation of lower authorities to follow higher judicial pronouncements.

4.5 It is a settled principle of law that rulings of the Tribunal and Courts are binding on subordinate authorities. The CAAR, being a statutory authority under the Customs Act, is equally bound by such precedents. To allow fresh application on questions already adjudicated by higher judicial for a would risk the creation of conflicting rulings and introduce uncertainty, an outcome contrary to the very object of the advance ruling mechanism. Clause (b) therefore operates as a statutory reinforcement of judicial discipline, making it explicit that once a question has been conclusively determined by the Tribunal or Courts, the Authority cannot re-adjudicate the same issue at the behest of another party.

4.6 In the instant case, I observed that the question raised in the present applications is squarely covered by the judgment of the Hon’ble Madras High Court in the case of M/s Shahnaz International Pvt. Ltd. [2023 (386) E.L.T. 214 (Mad.)], wherein the issue relating to the classification of Roasted Areca Nuts has already been examined and decided.

4.7 Further, I observe that the applicant has also raised the issue of availment of duty benefit of BCD under SI No. 172 of exemption Notification No 46/2011-Customs Dated 01.6.2011. This question raised was not covered in the judgment of the Hon’ble Madras High Court in the case of M/s Shahnaz International Pvt. Ltd. However, I note that the statutory framework governing advance rulings neither contemplates nor permits the partial rejection of an application. The scheme envisages that an application must be admitted or rejected in its entirety on the grounds expressly prescribed by the statute.

4.8 In view of the forgoing facts and records of the case, I am of the view that the issue raised in the instant applications is squarely covered by the judgement of Hon’ble Madras High Court in the case of M/s Shahnaz International Pvt. Ltd. [2023(386) E.L.T 214(Mad.)]. In terms of Section 28 I (2)(a) of the Customs Act, 1962 and in adherence to the principles of judicial discipline and binding precedent, I deem it appropriate to refrain from pronouncing any ruling on the question raised in the instant application regarding classification of the subject goods. Further, I find that the statutory scheme governing advance rulings does not envisage or permit partial rejection of an app7lication, therefore, the instant application is liable to be, and is accordingly, rejected in toto.

5. The application is not allowed and disposed of accordingly.