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Issues: Classification of "Roasted Betelnut/ Areca Nuts- Cut/Whole" for import - whether the goods are classifiable under Customs Tariff Heading 2008 19 20 (chapter 20) or under chapter 08 / chapter 21 headings.
Analysis: The classification is to be determined by the terms of the headings and relevant Chapter/Section Notes in the First Schedule to the Customs Tariff Act, 1975, applying the General Rules for Interpretation. The HSN Explanatory Notes are a safe guide for interpreting tariff headings. Heading 2008 (chapter 20) specifically includes dry-roasted, oil-roasted or fat-roasted nuts under tariff item 2008 19 20. The processes listed in chapter 08 notes (e.g., moderate heat treatment, dehydration) do not expressly include roasting; roasting denotes a more severe heat treatment producing fundamental chemical and physical changes distinguishable from mere drying or moderate heat treatment. Where a specific tariff entry exists for roasted nuts, that specific description prevails over a more general entry. Prior rulings and authorities addressing boiled or merely dried betel nut do not govern the classification of roasted betel nuts when a distinct roasted-nuts entry exists and when HSN Explanatory Notes expressly cover roasted nuts.
Conclusion: Roasted Betelnut/ Areca Nuts- Cut/Whole are classifiable under Customs Tariff Heading 2008, specifically tariff item 2008 19 20 (chapter 20).