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of <h1>Dark seedless dried grapes (Black Corinth) classified under CTI 08062010; exemption allowed after PQ/FSSAI verification.</h1> Dominant issue - classification under CTI 08062010: Applying the GRI and Chapter 08 notes, the Authority found the goods are dried grapes whose essential ... Classification on the import - Dark seedless Raisins - obtaining Advance Ruling u/s 28H - eligibility for customs exemption under Serial No. 32 of Notification No. 50/2017-Cus. - description of goods under Customs Tariff Heading 08062010 which pertains to 'Grapes, dried raisins' - Whether the DARK SEEDLESS RAISIN (subject goods) are classifiable under HS Code 08062010 ? - HELD THAT:- It is settled principle of law that the classification of any good under Customs Tariff Act, 1975 is governed by the General Rules for the Interpretation of the Import Tariff. Further, Rule 1 of GRI stipulates that 'classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes.' It is only when the headings and notes require otherwise that one may proceed to the subsequent rules. I observe that Chapter 08 of the First Schedule to the Customs Tariff Act covers 'Edible fruit and nuts; peel of citrus fruit or melons'. Heading 0806 specifically covers 'Grapes, fresh or dried'. Therefore, the starting point is an analysis of the terms of the heading 0806 read with the relevant Chapter/Section notes, legal context and statutory framework. The goods described as Dark Seedless Raisins are obtained from dark seedless grape varieties and are dried through natural or controlled processes without undergoing any treatment that alters their essential character. The ruling of the Customs Authority for Advance Rulings, Mumbai [2022 (5) TMI 1624 - CUSTOMS AUTHORITY FOR ADVANCE RULINGS, MUMBAI] wherein dehydrated dark and small seedless raisins were held to be classifiable under tariff item 08062010. Although advance rulings are binding only on the applicant and jurisdiction concerned, consistency in classification of identical goods is a desirable objective, particularly in the absence of any contrary judicial pronouncement or distinguishing factual circumstances. The impugned goods being dehydrated dark and seedless raisins appears to be classifiable under heading 0806. Custom Tariff Item (CTI) 08062010 covers raisins. Therefore, the goods under consideration are appropriately classifiable under CTI 08062010. Duty exemption: The raisins are the dried products of the grapes belonging to the family Vitis Vinifera. Therefore, if the goods to be imported satisfy the above-mentioned condition and are of seedless variety obtained from Black Corinth grapes, then they are classifiable under CTI 08062010 and will be eligible to avail benefit under Sr. No. 28 of the Notification 45/2025. In other words, on verification, if the product imported by the applicant is proved to be Vitis Vinifera, specifically Black Corinth grape variety, either by way of certification from PQ or FSSAI, or otherwise, then the appropriate classification will be CTI 08062010 and goods will be eligible for the said notification benefit. The applicant has failed to produce sample of the goods, actual photograph of the goods and PQ (Plant Quarantine) or FSSAI Certificate/license as mentioned. Further, the ascertainment with respect to the subject goods whether these are dark seedless raisins or not, depends on the production of PQ and FSSAI certificate/license and further verification of the subject goods to be imported vis-à-vis PQ and FSSAI certificate/license by the concerned port where the applicant intends to import the subject goods as the exemption benefit allowed under serial no. 28 of Notification no. 45/2025-Customs, dated 24.10.2025 is only available to dark seedless raisins. Thus, the dark seedless raisins (Vitis Vinifera) obtained from Black Corinth grapes merit classification under subheading 08062010 of the first schedule of the Customs Tariff Act, 1975 and are eligible for exemption benefit allowed under serial no. 28 of Notification no. 45/2025-Customs, dated 24.10.2025. Issues: (i) Whether dark seedless raisins (dehydrated seedless grapes of Vitis vinifera) are classifiable under tariff item 08062010; (ii) Whether such goods are eligible for customs duty exemption under the relevant exemption notification.Issue (i): Whether the subject goods merit classification under CTH 08062010.Analysis: Classification is governed by the General Rules for the Interpretation of the Import Tariff. Heading 0806 covers 'Grapes, fresh or dried' and subheading 080620 covers dried grapes with tariff item 08062010 specifically referring to 'Raisins'. The Harmonized System Explanatory Notes expressly include seedless raisins (including currants and sultanas) within the scope of the heading. The goods on record are described as dehydrated dark seedless raisins obtained from Vitis vinifera (Black Corinth variety) and undergo only dehydration and customary grading/packing without alteration of essential character. The jurisdictional customs commissionerate's comments and prior advance ruling on identical goods support classification under 08062010.Conclusion: The subject goods are classifiable under tariff item 08062010. (In favour of the assessee)Issue (ii): Whether the subject goods are eligible for customs duty exemption under the applicable notification.Analysis: Notification No. 50/2017-Cus. has been superseded by Notification No. 45/2025-Cus.; Serial No. 28 of Notification No. 45/2025 expressly lists dark seedless raisins falling under tariff item 08062010 as eligible for exemption. FSSAI Regulation 2.3.47 defines raisins as dried products of Vitis vinifera and provides standards; eligibility for the notification benefit requires that the imported goods satisfy these definitions and be verified by Plant Quarantine, FSSAI certification, or equivalent verification at the port of import. The applicant has not produced PQ/FSSAI certification or physical samples on record, but the description and submissions indicate the goods are dark seedless raisins of Vitis vinifera. The exemption is therefore available to such goods subject to verification of their conformity to the stated botanical variety and regulatory certification.Conclusion: Dark seedless raisins falling under tariff item 08062010 are eligible for customs duty exemption under Serial No. 28 of Notification No. 45/2025-Cus., subject to verification of conformity to Vitis vinifera (Black Corinth) and requisite PQ/FSSAI certification. (In favour of the assessee)Final Conclusion: The advance ruling determines that the products described as dark seedless raisins are classifiable as raisins under tariff item 08062010 and, upon verification of variety and regulatory compliance, are entitled to the exemption provided by Serial No. 28 of Notification No. 45/2025-Cus.Ratio Decidendi: Seedless dried grapes that are raisins of Vitis vinifera fall within tariff item 08062010; such goods, when established as dark seedless raisins of the specified botanical variety and meeting regulatory certification, qualify for the exemption under Serial No. 28 of Notification No. 45/2025-Cus.
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