https://www.taxtmi.com/caselaws?id=784587 Treated chilli seeds imported solely for sowing, rendered poisonous and unfit for human consumption, were held excluded from Chapter 09 as they are not "spices" or condiments; accordingly, departmental classification under CTI 0904 20 40/0904 22 12 was rejected. Applying Chapter 12 Notes and the Seeds Act definition, the goods were held classifiable as seeds for sowing under CTI 1209 99 90; Rule 3(a) of the GIR was found inapplicable for comparing eight-digit subheadings, and the impugned reliance thereon was erroneous; classification was granted as claimed by the importer. The extended period under s.28 could not be invoked absent a finding of suppression with intent to evade, especially where Bills of Entry were physically assessed; demand beyond the normal period failed. Appeal allowed and the appellate order was set aside. en-us Wed, 07 Jan 2026 00:00:00 +0530 Thu, 08 Jan 2026 08:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784587 Treated chilli seeds imported solely for sowing, rendered poisonous and unfit for human consumption, were held excluded from Chapter 09 as they are not "spices" or condiments; accordingly, departmental classification under CTI 0904 20 40/0904 22 12 was rejected. Applying Chapter 12 Notes and the Seeds Act definition, the goods were held classifiable as seeds for sowing under CTI 1209 99 90; Rule 3(a) of the GIR was found inapplicable for comparing eight-digit subheadings, and the impugned reliance thereon was erroneous; classification was granted as claimed by the importer. The extended period under s.28 could not be invoked absent a finding of suppression with intent to evade, especially where Bills of Entry were physically assessed; demand beyond the normal period failed. Appeal allowed and the appellate order was set aside. Case-Laws Customs Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784587