Flavoured Supari classified under tariff heading 2106 90 30 and granted customs duty concession under Notification 68/2012.

Flavoured supari, being a processed preparation of betel nut subject to cleaning, cutting, dehydration and flavouring, falls within the description of betel nut product under Chapter 21 and supplementary note 2, and thus merits classification under tariff heading 21069030. Application of the General Rules of Interpretation favouring the most specific description over the general areca nut entry dictates this classification. Reliance on a CBIC circular clarifying scented sweetened supari classification supports this view. Consequently, goods classifiable under 21069030 qualify for the customs duty concession under Serial No. 39 of Notification No. 68/2012-Customs.

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Issues: (i) Whether the imported "Flavoured Supari" is classifiable under Heading 2106, Sub-heading 210690 and Tariff Item 21069030 of the First Schedule to the Customs Tariff Act, 1975; (ii) If so, whether the goods qualify for concession of basic customs duty under Sr. No. 39 of Table 1 of Notification No. 68/2012-Customs dated 31.12.2012.

Issue (i): Whether "Flavoured Supari" (a preparation from betel/areca nut with added scents/flavours and not containing lime, katha or tobacco) falls under CTI 21069030 or under Chapter 8 (e.g., 08028090).

Analysis: The Authority applied the General Rules for Interpretation (GIR), relevant Chapter and Supplementary Notes and explanatory materials. Supplementary Note 2 to Chapter 21 expressly defines "betel nut product known as Supari" as any preparation containing betel nuts but not containing lime, katha (catechu) or tobacco, and contemplates additions such as menthol. Where goods are prima facie classifiable under more than one heading, Rule 3(a) requires preference for the heading providing the most specific description. The Authority considered competing Chapter 8 provisions (nomenclature and Note 3 treatments) and held that the processes and additives described produce a specific preparation addressed by the Chapter 21 supplementary note. The Authority also considered and applied CBIC Circular No. 163/19/2021-GST and the legal framework including Section 3(7) of the Customs Tariff Act to ensure consistency between customs classification and IGST/CGST treatment, and followed binding jurisdictional High Court precedent supporting classification under Chapter 21 where applicable.

Conclusion: The Authority held that the subject goods merit classification under Heading 2106, Sub-heading 210690 and Tariff Item 21069030 (betel nut product known as "Supari").

Issue (ii): Whether goods classifiable under 21069030 are eligible for concession under Sr. No. 39 of Table 1 of Notification No. 68/2012-Customs dated 31.12.2012.

Analysis: Sr. No. 39 of Table 1 of Notification No. 68/2012 extends concession of basic customs duty to goods classified under Chapter 21 except specified alcoholic compound preparations. Having concluded that the goods fall within tariff item 21069030 of Chapter 21 and that they are not excluded by the exception in Sr. No. 39, the Authority applied the notification's terms to the classified item.

Conclusion: The Authority held that the goods classified under CTI 21069030 are eligible for the concession of basic customs duty under Sr. No. 39 of Table 1 of Notification No. 68/2012-Customs dated 31.12.2012.

Final Conclusion: The Advance Ruling Authority allowed the applicant's CAAR-1 application, ruling that the imported "Flavoured Supari" is classifiable under CTI 21069030 and is eligible for the specified customs duty concession under Notification No. 68/2012-Customs; the application is allowed and the ruling is issued in favour of the applicant.

Ratio Decidendi: Where a specific tariff entry and supplementary note in Chapter 21 expressly covers a preparation ("Supari") containing betel nuts and excluding lime, katha or tobacco, the specific entry prevails over the general description in Chapter 8; therefore such flavoured betel-nut preparations are classifiable under Heading 2106 (CTI 21069030) and, if not otherwise excluded, attract concessions applicable to Chapter 21 entries.

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