Tariff classification of roasted areca nut follows the specific entry for roasted nuts, not the dried areca nut heading.

Roasted areca nut or betel nut, whether whole, split or cut, is classified under heading 2008 19 20 because Chapter 20 specifically covers roasted nuts and the HSN notes expressly include roasted areca or betel nut. The Court held that roasting is a distinct process from drying or boiling, so Chapter 8, which covers fresh or dried areca nuts, does not apply. It further held that the common parlance test cannot displace the specific tariff entry, and that the Revenue's relied-on precedents were inapposite because they dealt with boiling, drying, or supari preparation rather than roasted areca nuts. The advance ruling was upheld.

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Issues: Whether roasted areca nut or betel nut, in whole, split or cut form, is classifiable under heading 2008 19 20 of the First Schedule to the Customs Tariff Act, 1975, or under heading 0802 as fresh or dried areca nut.

Analysis: The classification turned on the tariff scheme, the chapter notes and the Harmonised System of Nomenclature. Chapter 8 covers fresh or dried areca nuts, while the chapter notes treat drying as a distinct process of preservation or stabilization. Chapter 20, by contrast, specifically includes roasted nuts, and the relevant HSN notes expressly mention roasted areca or betel nuts under that chapter. The Court held that roasting is a distinct process from drying or boiling, and that the presence of a specific tariff entry for roasted nuts means the common parlance test cannot override the statutory classification. The Court also held that the competing precedents relied on by the Revenue did not decide the present question, because they concerned boiling, drying or preparation of supari and not roasted areca nuts.

Conclusion: Roasted areca or betel nut is classifiable under heading 2008 19 20, not under heading 0802, and the advance ruling was upheld.

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