Specific tariff entry for roasted areca nuts prevails over the general Chapter 8 heading for treated nuts.

Roasted areca nuts, including whole, split and cut forms, are classified under Heading 2008 19 20 as other roasted nuts and seeds rather than under Chapter 8 as dried or otherwise treated areca nuts. The tariff analysis turns on the specific entry for roasted nuts, read with the HSN Explanatory Notes, which expressly include dry-roasted, oil-roasted and fat-roasted areca or betel nuts within Heading 2008. Because roasting materially alters the nuts and fits the specific roasted-nuts description, the more general Chapter 8 heading for treated nuts does not apply.

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Issues: Whether roasted areca nuts, namely whole, split and cut forms, are classifiable under Heading 2008 19 20 of the Customs Tariff Act, 1975, as other roasted nuts and seeds, or under Chapter 8 as dried or otherwise treated areca nuts.

Analysis: Chapter 8 covers fruits and nuts subjected to processes such as drying, boiling, steaming, chilling and provisional preservation, and its note permits limited treatment for additional preservation or stabilization. Roasting, as described in the record, involves repeated high-heat cycles that materially alter the physical and chemical characteristics of the nut and is distinct from moderate heat treatment or dehydration. Chapter 20 applies to preparations otherwise prepared or preserved, and the HSN Explanatory Notes specifically include areca or betel nuts that are dry-roasted, oil-roasted or fat-roasted within Heading 2008. In resolving the competing entries, the specific tariff description, supported by the HSN Notes, prevails over the more general Chapter 8 description.

Conclusion: Roasted areca nuts are classifiable under Heading 2008 19 20 of the Customs Tariff Act, 1975, and not under Chapter 8.

Final Conclusion: The classification dispute is resolved in favour of the applicant, and the impugned goods are accepted as roasted nuts under the specific tariff entry for roasted nuts and seeds.

Ratio Decidendi: Where the tariff contains a specific entry for roasted nuts and the HSN Explanatory Notes expressly include roasted areca nuts, classification must follow that specific entry rather than the general chapter for dried or otherwise treated nuts.

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