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    Diversion of income by overriding title shields liquidation receipts from tax where statutory application diverts realizations at source.
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      Classification of a fortified soy protein product turned on the...

      Protein-based food preparation classification favours Heading 2106 over Heading 3504 for fortified soy product.

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      CustomsJune 18, 2026Case LawsAAR
      Classification of a fortified soy protein product turned on the tariff terms, Chapter Notes and the General Rules for Interpretation rather than food-standard labels. Although Heading 3504 covers protein isolates, the product's 82% protein content, added calcium phosphate and fortified imported form showed it was not a plain soy protein isolate but a formulated nutritional preparation. The reliance on Codex and FSSAI standards was non-determinative for customs classification. Applying the HSN Notes to Heading 2106 and Chapter Note 5 to Chapter 21, the product was treated as a protein-based food preparation for enrichment of foods and beverages, and tariff item 21061000 was preferred over Heading 3504.

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      ActsIncome Tax