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Issues: (i) Whether dehydrated dark and small seedless raisins (Vitis vinifera) are classifiable under subheading 08062010 of the First Schedule to the Customs Tariff Act, 1975; (ii) Whether the said goods are eligible for exemption under Sr. No. 32 of Notification No. 50/2017-Cus. dated 30.06.2017.
Issue (i): Whether dehydrated dark and small seedless raisins (Vitis vinifera) are classifiable under subheading 08062010 of the First Schedule to the Customs Tariff Act, 1975.
Analysis: Chapter 8 covers edible fruits and nuts, including dried grapes. The explanatory notes to heading 0806 specifically include dried grapes such as currants, sultanas and seedless raisins. The goods described as dehydrated dark and small seedless raisins fall within that heading, and subheading 08062010 covers raisins. The product was also treated as raisins of Vitis vinifera on the basis of the material placed and the definition of raisins referred to in the FSSAI regulations.
Conclusion: The goods are classifiable under subheading 08062010 of the First Schedule to the Customs Tariff Act, 1975.
Issue (ii): Whether the said goods are eligible for exemption under Sr. No. 32 of Notification No. 50/2017-Cus. dated 30.06.2017.
Analysis: Sr. No. 32 covers dark seedless raisins. Since the impugned goods are dehydrated dark and seedless raisins, they satisfy the description of the exempted goods. The ruling also proceeds on the basis that if the product is verified as Vitis vinifera by the competent authority, the benefit of the notification would follow.
Conclusion: The goods are eligible for exemption benefit under Sr. No. 32 of Notification No. 50/2017-Cus. dated 30.06.2017.
Final Conclusion: The application succeeds and the impugned goods were held to be classifiable as raisins under subheading 08062010 with the corresponding customs exemption benefit.
Ratio Decidendi: Dried grapes answering the description of seedless raisins under heading 0806 are classifiable as raisins, and goods matching the exempted description in the relevant notification are entitled to the exemption.