Tariff classification of prepared pulses turned on HSN Explanatory Notes, placing the goods under Chapter 20.

Prepared and packed goods made from rajmah, lobia, kabli channa, black channa and mah ki dal were held classifiable under Chapter 20 rather than Heading 2108.99 because the tariff did not specifically define these beans and pulses and HSN Explanatory Notes were used to resolve the ambiguity. On that basis, Chapter 7 was treated as covering the raw pulses, while Chapter 20 covered products of Chapter 7 that had been prepared or preserved by processes beyond those excluded by the chapter note. The classification claim accordingly succeeded.

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Issues: Whether the goods manufactured from rajmah, lobia, kabli channa, black channa and mah ki dal were classifiable under Heading 2001.10 of the Central Excise Tariff Act, 1985 or under Heading 2108.99.

Analysis: The goods were prepared by washing, cooking and mixing with tarka and were packed without preservative. The tariff contained no specific definition for these beans and pulses, so assistance was taken from the HSN Explanatory Notes. On that basis, Chapter 7 covered peas, beans and lentils, while Chapter 20 covered only those products of Chapter 7 that had been prepared or preserved by processes other than those referred to in Chapter Note 1(a). The Tribunal also distinguished the cited precedent relating to samber mix and rasam mix, and relied on the principle that HSN Explanatory Notes may be used to resolve classification disputes.

Conclusion: The goods were classifiable under Chapter 20 and not under Heading 2108.99; the assessee's classification claim succeeded.

Ratio Decidendi: For tariff classification, where the statute is unclear, HSN Explanatory Notes may be used to determine whether a product falls within a chapter covering prepared or preserved goods of the relevant vegetable or pulse category.

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