Mixed-product tariff classification for carbonated fruit juice beverages falls under the equally relevant heading, not carbonated flavoured water.

Carbonated beverages with fruit juice were held classifiable under tariff item 2202 99 20, not as carbonated flavoured waters under tariff item 2202.10. The classification turned on the General Rules for Interpretation of the Customs Tariff: a mixed product is not classified only by its predominant ingredient, the most specific description prevails, and where competing headings remain equally applicable after Rules 3(a) and 3(b), Rule 3(c) applies. Because both the carbonated and fruit-juice components contributed to the product's essential character, neither component could be treated as the sole basis of classification. Binding precedent on the same product category supported this result.

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Issues: Whether carbonated beverages with fruit juice were classifiable under tariff item 2202 99 20 as fruit pulp or fruit juice based drinks, or under tariff item 2202.10 as carbonated flavoured waters, for the purpose of IGST.

Analysis: The goods were sold as carbonated beverages with fruit juice and were recognised in the FSSAI regulations as a distinct category. The classification dispute had to be resolved under the General Rules for Interpretation of the Customs Tariff, especially the principles that a mixed product is not classified merely by the predominant ingredient, that the most specific description prevails, and that where competing headings each merit consideration and neither Rule 3(a) nor Rule 3(b) resolves the matter, Rule 3(c) applies. On that basis, the product could not be treated as carbonated water alone or as fruit juice alone, since both components contributed to its essential character. Tariff item 2202 99 20, being the last equally relevant heading, was therefore the proper classification. Earlier binding precedent on the same product category supported this view.

Conclusion: The goods were correctly classified under tariff item 2202 99 20 and the Revenue's classification under tariff item 2202.10 was rejected.

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