Customs classification of betel nuts depends on actual product character, not FSSAI reports, with advance rulings limited to their facts.

Customs classification turns on the actual character of the imported goods as established by tariff-relevant evidence and the applicable chapter notes. An FSSAI laboratory report was treated as relevant only to fitness for human consumption and not as a basis for tariff classification. The CRCL report, read with later clarification, was accepted as reliable and supported treatment of the goods as whole betel nuts rather than boiled supari. Advance rulings cited by the importers were held applicable only to the specific applicants and different factual matrices. On the facts, the goods were classifiable under CTH 0802 80 10 and not under CTH 2106 90 30.

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Issues: (i) Whether the FSSAI laboratory report could be relied upon for customs tariff classification of the imported goods; (ii) Whether the CRCL test report was complete and reliable for determining whether the goods were boiled supari or whole betel nuts; (iii) Whether the advance rulings relied upon by the appellants governed the present imports; (iv) Whether the imported goods, on the facts and the tariff notes, were classifiable under CTH 2106 90 30 or CTH 0802 80 10.

Issue (i): Whether the FSSAI laboratory report could be relied upon for customs tariff classification of the imported goods.

Analysis: The FSSAI-notified laboratory report was treated as relevant only to the fitness of the goods for human consumption. It did not determine tariff classification under the Customs Tariff. Classification had to be decided on the basis of the customs law framework and the nature of the goods as tested and described for tariff purposes.

Conclusion: The FSSAI report could not be used as the basis for tariff classification.

Issue (ii): Whether the CRCL test report was complete and reliable for determining whether the goods were boiled supari or whole betel nuts.

Analysis: The customs laboratory report stated that the sample was in the form of whole betel nut and was free from cardamom and food starch, while the clarification obtained later confirmed that the goods were not a preparation and fell under Chapter 8. The report, read with the clarification, supplied the decisive scientific basis for classification.

Conclusion: The CRCL report was accepted as reliable for classification and supported treatment of the goods as whole betel nuts.

Issue (iii): Whether the advance rulings relied upon by the appellants governed the present imports.

Analysis: Advance rulings were held to bind only the applicant who sought them and the customs authorities in relation to that applicant. The rulings cited by the appellants related to different applicants and different factual matrices, including processed products containing additives such as starch, and therefore did not control the present case.

Conclusion: The cited advance rulings were inapplicable to the appellants.

Issue (iv): Whether the imported goods, on the facts and the tariff notes, were classifiable under CTH 2106 90 30 or CTH 0802 80 10.

Analysis: The tariff scheme, Chapter 8 notes, and Chapter 21 supplementary notes were applied to the goods as found on test. The goods remained whole betel nuts, free from the ingredients and processing that would convert them into a supari preparation under Chapter 21. Mere boiling, drying, and rehydration did not alter the character of the nuts so as to shift them out of Chapter 8.

Conclusion: The goods were correctly classifiable under CTH 0802 80 10 and not under CTH 2106 90 30.

Final Conclusion: The classification adopted by the department was upheld, and the appellants failed to establish that the imported consignments had acquired the character of supari preparations covered by Chapter 21.

Ratio Decidendi: For customs classification, the decisive test is the actual character of the goods as established by reliable tariff-relevant evidence and the applicable chapter notes; advance rulings bind only the applicant and do not govern different importers with materially different facts.

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