Manufacture and tariff classification of processed dry fruits under Chapter 20 upheld after prior connected ruling

Processing of dry fruits, peanuts, pista, cashewnuts and almonds was treated as manufacture for Central Excise purposes, making the goods classifiable under Chapter 20 of the Central Excise Tariff Act, 1985. The SC noted that the products and processing were materially similar to those considered in a connected matter, where the same treatment had already been upheld, and no reason was found to depart from that view. On that basis, the Tribunal's alignment with the earlier ruling was maintained and the assessee's appeal failed.

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Issues: Whether the processing of dry fruits, peanuts, pista, cashewnuts and almonds amounted to manufacture and rendered the goods classifiable under Chapter 20 of the Central Excise Tariff Act, 1985.

Analysis: The products involved were similar to those considered earlier in a connected matter, where the same line of processing was held to amount to manufacture and the goods were held classifiable under Chapter 20. As the present case involved the same question and the Tribunal's view aligned with that earlier decision, no separate departure from that ruling was warranted.

Conclusion: The processing amounted to manufacture and the goods were classifiable under Chapter 20 of the Central Excise Tariff Act, 1985; the assessee's appeal failed.

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