Roasted areca nut classification favoured Chapter 20, with HSN notes treating dry-roasted and oil-roasted nuts as preparations.

Roasted areca nut, including roasted areca nut cut, was classified under sub-heading 2008 19 20 of the Customs Tariff Act, 1975 as other roasted nuts and seeds, not under heading 0802 as dried areca nuts. The authority applied the tariff scheme by noting that Chapter 8 covers edible fruit and nuts and permits only the processes specifically contemplated in its notes, including moderate heat treatment for preservation or appearance, whereas roasting is excluded. Chapter 20 was preferred because its HSN Explanatory Notes specifically include areca or betel nuts that are dry-roasted, oil-roasted or fat-roasted, and the specific tariff description in heading 2008 prevailed over the more general heading 0802.

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Issues: Whether roasted areca nut, including roasted areca nut cut, is classifiable under sub-heading 2008 19 20 of the Customs Tariff Act, 1975 as other roasted nuts and seeds, or under heading 0802 as dried areca nuts.

Analysis: The goods were found to undergo a process of roasting involving high heat, repeated heating and cooling, and substantial reduction of moisture content, resulting in a product different from dried or merely moderately heat-treated areca nut. Chapter 8 covers edible fruit and nuts and permits only the processes specifically contemplated by its notes, including moderate heat treatment for preservation or appearance, while roasting is not one of those processes. Chapter 20 covers preparations of vegetables, fruit, nuts or other parts of plants, and its HSN Explanatory Notes specifically include areca or betel nuts that are dry-roasted, oil-roasted or fat-roasted. The HSN was treated as a safe guide for classification, and the specific tariff description in heading 2008 was preferred over the more general heading 0802.

Conclusion: Roasted areca nut, including roasted areca nut cut, was held classifiable under sub-heading 2008 19 20 of the Customs Tariff Act, 1975 and not under heading 0802.

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