CUSTOMS AUTHORITY FOR ADVANCE RULINGS

5TH FLOOR, NDMC BUILDING, Y ASHWANT PLACE, SA TY A MARG,

CHANAKYAPURl, NEW DELHI-110021

[Emai l :e-u s-advru l ings.del <'a \gov .i n]

Present

(Customs Authority for Advance Rulings, New Delhi)

Vijay Singh Chauhan

The day of 315t May, 2021

Ruling No. CAAR/Del/Naman Agri/09/2021 \ .,,,.-7

In Application No. VIll/(CAAR)/Delhi/Naman Agri/05/2021 ) \.\,Cl, f- {,

~L,y-J 'l!> ?/
Mis Naman Agri ltnpex Private Ltd.,
Name and address of the applicant:
E-4/23A, Model Town-1 ,
New Delhi-110009

Principal Commissioner of Customs,

Commissioner concerned:
NS-l, JNCH , Nhava Sheva,Tal-Uran ,
District- Raigad, Maharashtra-400707

Principal Commissioner of Customs,

(Preventive), (CPC), 55-17-3 , C-14,
2nd Road, industrial Estate,
Auto Nagar, Vijayawada-520007
(A.P.)

Commissioner of Customs,
O/o the Pr. Commissioner o f
Custom s, Custom House , M undra,
SB, Port User Build ing, Mundra

Pa_ge-~t::ttJ:::::,....._

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 Port, Mundra, Kutch,
Gujarat-37042 l

Shri Somesh Arora, Advocate

Present for the Applicant:

None
Present for the Department:

Ruling

M/s Naman Agri lmpex Private Ltd., New Delhi, a resident proprietorship firm ha~i•ng_ [EC No.
AAACR6259H and PAN AAACR6259H, (M/s Naman, in short) has filed an application dated
25.01.2021 seeking advance ruling under section 28-H of the Customs Act, I 962 before the
Customs Authority for Advance Rulings, New Delhi (CAAR, in short).

2. On scrutiny of the application, Secretary, CAAR, New Delhi issued Deficiency Memo and
requested the applicant to rectify the said deficiencies. Rectification of deficiency was completed
by the applicant and rectified application was submitted vide letter dated 19.02.2021 of their
co~nsel, Shri Somesh Arora which was received in the Secretariat of CAAR, New Delhi on
0].'03 .2021. The application was accordingly registered under serial No. 02/2021-Delhi dated
0l.03.2021.
3. On registration of the application, the concerned Principal Commissioner/Commissioner of
Customs were requested vide letter dated 05.03.2021 to furnish their comments, in the matter. fn
this regard, comments of the concerned Commissioner of Customs, Custom House, Mundra, has
been received, wherein it is inter-alia stated that it is undoubtedly clear that Areca Nut dried also
known as supari whole or split, are rightly classifiable under CTH 0802. Further, referring to the
Chapter Notes of Chapter 8, it is stated that since the applicant submitted that they are going to
import whole raw green fresh B~tel Nut/boiled Betel Nut; Chikni Supari; Unflavoured S\lpari; and
Flavoured Supari, which is not in powder form, the product "Betel Nuts" rightly falls under CTH
0802 of Customs Tariff Act, 1962. Further, since whole raw green fresh Betel Nut/boi'led Betel Nut
do not faIJ under CTH 21069030 benefit of exemption of Notification No. 50/20 l 7-Customs dated
30.06.2017 listed under Sr. No. 103 of the Table under the said Notification is not avaUable to the
commodities (betel nuts).

4. Jn accordance with the procedure prescribed under the CAAR Regulations, 2021, personal
hearing was scheduled on 26.04.2021. However, counsel of the applicant requested for another
date for hearing due to extension of lockdown 1n Delhi. Keeping in view the statutory provisions
under section 28-1 of the Customs Act, 1962 that require ruling to be pronounced within three

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rcr A1var.u r.i:, 11

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I .
months of filing of the application , next date of personal hearing was txe
f don 25 05 202 l in virtual

mode, keeping in view the circumstances prevailing on account of C?V~D pan edmic.
Representing the applicant, Shri Somesh Arora, Advocate, atten d ed e e
· · d .
th h aring m virtual mo e on
.
. ti d b t th classification question
the said date. During the hearing, the leamed advocate brie e a ou e .
. . . fl · l . d th processes earned out to
and products on which ruling has been sought. He bne y exp ame e .

r
, . ed . h · 1· f10 n for Advance Ruling.
obtain 5 different types o1 betel nut products as mention mt eir app 1ca .
10
.
He referred to the two previous rulings of the Authority for Advance Rulings {AAR, short) m
the case of Mis Excellent Betelnut Products Pvt. Ltd. and Mis Oliya Steel Private Ltd. Learned
advocate stressed upon the binding nature of earlier decisions of the AAR referring to various
decisions, wherein it is held that principle of law laid down has to be followed and same should
not be ignored in future rulings. He also mentioned that earlier rulings of AAR were bestowed a
status higher than a decision of the Tribunal by the CEST AT. He further stated that in case the
precedence of earlier decision of the AAR is not followed, it will lead to anomalous situation where
at one particular Customs Station, a product may get classified in two different headings of the
Import Tariff on the basis of two different rulings by AAR/CAAR. Shri Arora promised to submit
a written brief of the submissions made during the PH by the end of the day.

4.1 After the personal hearing, Shri Arora sent an email containing synopsis of submissions made
during virtual hearing, wherein it is inter-alia stated that with reference to query raised during
hearing by the Ld. Authority for Advance Ruling with regard to addressing the question as to when
an item continues to remain within its raw or permissible processed form, and when it becomes
the preparation, it is submitted that the question was duly addressed in the enclosed ruling of Mis
Excellent Betelnut Products Pvt. Ltd., Nagpur in Para 5, 6, 7 & 10 and also in Para l O of the
decision of M/s Oliya Stee1 Pvt. Ltd. , Kolkata, which after considering the relevant headings of
Chapter 8 and Chapter 21 as well as the Chapter Note concluded that Betel nuts once boiled etc.
go beyond the description of " Fresh and Dried" and enter the domain of preparation. Attention is
also drawn to 2018 (363) E. L. T. 1039 (Tri.- Mum.), in the matter of HLL Life Care Ltd. Vs.
Commissioner of Customs, (ACC & Jmports), Mumbai, (enclosed in Synopsis) which though is a
decision in favour of the Revenue decides as to when a product ceases to be as per its original
Tariff Entry and moves on to become a preparation. In Para 4 (reproduced below) the Lordships
observed as follows:

Para 4:

" From the plain reading of above both the Tariff Entries it is seen that Heading
No ,3006.60. 10 is not fo r the basic hormones but it is meant for preparation of chemical
contra~eptives based on Hormones. Therefore, the product falling under Chapter HeadinR
3006 1s a preparation which is one step ahead of the basic Hormones and the Bas'ic
Hormones are correctly classifiable under Heading 2937." (E mphasis supplied).
 . fi fol tows that some
I mentioned that it there ore, d ain of
Jn the light of the above, learned counse ·t· ried out moves it to the om d
h basic product I car as observe
processing and even one process on t e . k'10dly be noted that, as W
11
(Preparation) as for as Customs Tariff is concerned; may • ciple was laid down that
. . , .
in both the Advance Ruling Authority s ru 1mgs ct
h
'ted above that t e prm r
.
. 'bl to fall under the descnp ton
. .. . . h b I t tobecaltedase 11g1 e •ff At
process even 1fboilmg d1 sent1tled l e ete nu 5 • . , •
0802 of the Customs Tan · c'
'betel nuts fresh and dried' falling under C uSlOms Tan ff Heading R ling Authority are worthy
1975. Lastly, it is prayed that the considered Rulings of the Advance u
of following and it is therefore, pleaded accordingly.
. d tails and processes involved in
5. The applicant wishes to import various type of products, e
making of the same are summari zed as under:
h betel nut: removing of
ti
(i) 'API Supari': Following processes are conducted on raw green res · . . . .
Jarge impurities by labourers, boiling in water for 6 hours, mixing food starch, drymg, pohshmg
and packaging.

(ii) 'Chikni Supari': Following processes are conducted on raw green fresh betel nut:_r~moving
of large impurities by labourers, slicing in small pieces, boiling in water for 6 hours, mix mg food
starch, drying, polishing and packaging.

(iii) 'Unflavoured Supari': Following processes are conducted on raw dried betel nut: removing
of large impurities by labourers, removing of small impurities by de-stoner, metal deflection
(removal of metal item, if any), garbling, polishing in polishing machine, 3 stage cutting, blowing
of weightless particles in blowers, gravity separation by automatic gravity separation machine,
roasting in fire gas rotary roaster, rnetal detection by magnetic metal detectors and packa_~.ing.
These beteJ nuts wiJJ be cut into 8 or 12 pieces.

(iv) 'Flavoured Supari': Following processes are conducted on .raw dried betel nut: removing of
large impurities by labourers, removing of small impurities by de-stoner, -metal deflection (removal
of meta.I 'item, if any), garbling in automatic garblers, polishing in ·polishing machine, sterilization
to remove bacterial count, 3 stage cutting, blowing of weightless particles in blowers, gravity
separation by automatic gravity separation machine, roasting in fire gas rotary roaster, flavoring
in large size automatic blenders with compound, metal deflection by magnetic metal deflectors,
sterilizing to kill bacteria count increased due to handling in processing and packaging. Then
flavors such as flavoring materials like spices/or mulethi etc. are mixed in automatic blenders with
outsourced liquid flavors such as perfumes etc. in mega size automatic blenders with compound .

.(v) 'Boiled Supari': Following processes are conducted on whole raw green fresh bete l nut :
removing of 1arge impurities by labourers, boiling in water for upto 4 hrs, removing the husk ,
boiling again for 2 hours, drying by hot air, ·sterili zing, sorting, polishing and packaging whole
boiled betel nut.
 After mentioning above details and processes involved in making of various type of Supad, the
question (as stated in para 4 of Annexure l) on which advance ruling has been sou8ht is,

"As to whether the products described as ahove and known as API supari. Chikni supari,
Flavoured supari, Unflavoured supari and Boiled supari merit classification in Chapter 8 (Iariff
Heading 08029000) or under Chapter 21 of Customs Tar~ff''.

However, in column 8 of Form CAAR-1, the applicant stated the following questions on which
ruling has been sought,

"Whether the goods sought to be imported is processed whole betel nut as described therein above,
whether or not containing ingredients such as food starch, spices, mulethi, flavors, perfume etc.,
though not containing lime or katha (catechu) or tobacco and will the resultant products viz. (i)
AP1 supari (processed whole raw green fresh betel nut/boiled betel nut), (ii) Chikn1 supari, (iij)
Unflavoured supari, (iv) Flavoured supari, (v) Boiled supari are classifiable under the
Chapter/Heading 21069030?",

"Whether the finished products are rightly classifiable under 21069030 though the raw material
used for the manufacture falls under CTH 08029000?" and

"'Whether the Notification No. 50/2017-Customs dated 30.06.2017 is applicable and if so whether
the benefit of exemption listed under Sl. No. l 03 of the Table under the said notification is
available to the commodities (products manufactured out of betel nuts) under CTH 21069030?"

6. I find that the concerned Principal/Commissioner of Customs have not provided their
comments to this specific advance ruling application~ even as their comments on question relating
to classification of same goods are available with this Authority. Therefore, recognizing the
importance of timely issue of advance ruling orders and finding that the application is valid in
terms of the provisions of the Customs Act and the CAAR Regulations, 202 l, having heard the
applicant and recognizing the importance of timely pronouncement of rulings, l proceed to
examine the questions on merit.

7. The applicant has explained the processes involved in making five different products, as stated
in para 5 above. The applicant has contended that from the processes mentioned above, it is clear
that though the end-products use betel nut/ areca nut as the main raw material~ in the process
various other products are mixed and therefore, the products become a preparation. Hence these
goods fall under the Chapter 21 and more particularly in CTH 21069030; and not under Chapter
8. The applicant has also referred to the Supplementary Note 2 of Chapter 21 to justify that these
products are classifiable under the Sub-heading 2106 90 30. As per the said Supplementary Note
I
. containing betel
reparation h )
Supari" means any P 1· katha (catec u
. 1N duct known as .. amely ime, "
2: " In this chapter '·Bete ut pro . c. llowing ingredients, n ra or menthol.
. .
nuts but not contammg any one o: .
more of the io
ther ingredients such as car
darnorn cop
. ' . the case of Mis
and tobacco whether or not containing any o twhile AAR New Deihl in ·11 revert to
t ling of the ers ' K lkata I wt
They have also cited reference o ru . S I Private Limjted, . o .
Excellent Betelnut Products Pvt. Ltd, Mis Oltya tee
these in my discussion later in the 0rd er. .
"th the cited reference to the ruhng
r t along WI . ds
8. On the basis of the submissions of the app ican '. . h CTH for the aforesaid five goo '
of the erstwhile AAR there are two conte nd ing enmes t e
10
. uld be useful to carefully
' d" 0802 80 90 Therefore, it wo .
viz. sub-heading 2106 90 30 and sub-hea mg · • h reto
consider the two competing tariff entries and the guidance relating t e ·
. ·1 . fruit or melons includes, inter
9. Chapter 8, which covers Edible fruit and nuts; peel of Cl rus
alia, the following Note 3: -
. . . h drated or treated for the
'3. Dried fruits or dried nuts of this Chapter may be partw11Y re '.Y '
following purposes:
a.
. . . . (fi
For additional preserv.ation or stabrhzatzon 1 b moderate heat treatment,
or examp e, Y
sulphuring, the addition of sorbic acid or potassium sorbate);
b. To improve or maintain their appearance (for example, by the addition of vegetable oil or
small quantities of glucose syrup),
provided thai they retain the character of dried fruit or drted nuts. '
IO. In the Chapter 8, areca nuts, whole, split, ground, and two residuary sub-headings are
accommodated under 08028010, 2-0, 30, 90, and 08029000, respectively.

11.1 On the other hand, Chapter 21 covers miscellaneous edible preparations. The relevant
Supplementary Note 2 to the said Chapter lays down that,

'In this ChapJer ''betel nut product kn.own as Supari " means a11y preparation containing betel
nuts, but not containing any one or more of the following ingredients, namely: lime, katha
(catechu) and tobacco whether or not containing any other ingredients, such as cardamom, copra,
menthol. '

_I 1.2 In this Chapter, the related entry, with respect to betel nuts, is the sub-heading 21069030,
1.e., betel nut products known as supari.

l~. Further, sinc_e the question r~lates to classification of goods proposed to be imported, guidance
ot th~ H_armonize~ Com_m?d1ty_ Description and Coding System of the World Customs
Orgamzat1on, to ,~h1ch India 1s a _signatory, would be useful. It is seen that with respect to Chapter
8, the HSN prescribes the following as general guidelines: -
'Fruit and nuts o[ this Chapter mav be ·whole, sliced. chopped, shredded. sto~ed oul d d
peeled or shelled. · • - pe , grate .
 The addition ofsmall quantities ofsugar does not affect the classification offru it in !his Chapter. ·
1J. Further, on perusal of the advance rulings given by the erstwhile AAR, New Delhi, which
have been referred to by the applicant, I find that case of Mis Excellent Betel nut Products Pvt. Ltd.
do cover the four goods, i.e. AJ>I supari, Chikni supari , Unflavoured supari and Flavoured supari ,
involved in the present prooeedings; and in both these rulings, the erstwhile AAR has concluded
that the said products merit classification under sub-heading 21069030. I find that in reaching th is
conclusion, AAR has been of the view that on account of the positive language of the
Supplementary Note 2 to Chapter 21, it is not necessary for betel nut (supari) to undergo a change
of character for it to be classified under Chapter 21. I also find that the AAR had considered the
contention of the depa,tment that the said four goods merit classification under Chapter 8, but
rejected the same. However, while doing so, the erstwhile AAR did not make any comment on the
implications of the Chapter Note 3 to Chapter 8 on the processes that raw betel nuts were subjected
to obtain the said four goods. Further, AAR was of the opinion that the decision of the Hon'ble
Supreme Court in the case of Mis. Crane Betel Nut Powder Works reported at 2007 (210) E.L.T ·
171 (S.C.) has no application in the facts of the cases before them. It is my considered opinion that
in order to arrive at the appropriate classification of the said four goods, all originating from
common source viz. raw green fresh betel nut, a more comprehensive view needs to be taken than
.in the aforesaid Mis Excellent Betelnut case.

14. Having gone through the ,advance ruling application, supporting arguments for
classification -of the five goods under Chapter 21 as preparations of betel nuts, precedence of
erstwhile AAR in support of the said classification, I summarize the contending positions on the
question posed for advance ruling.

15. Advance ruling has been sought on classification of five different goods, each known as
"supari" in common trade parlance, albeit with differentiator, viz. API, Chikni, unflavoured,
flavoured and Boiled. The basic raw material for each of the five goods is raw betel nut, which is
classifiab.le under Chapter 8, more specifically sub-heading 080280. I also note that Chapter 8
covers only edible nuts; inedible nuts and fruits being excluded by virtue of Chapter Note I ; and
that betel nut/supari are masticatory. However, these items have been subjected to certain
processes and added with certain materials, resulting in the question being posed whether the said
processes and mixing/addition of certain materials are substantive enough to lead to the said five
goods be considered as "preparation of betel nut" that would make them classifiable under Chapter
21 by virtue of Supplementary note 2 of Chapter 21. lt is the contention of the applicant that due
to the processes that the raw betel nuts have been subjected to, the goods have become preparations
of betel nuts. Alternatively, whether the processes carried out on the same for cleanino0 preservino
0
an d mak'mg them more attractive to certain tastes/ preferences are too minor to fal '
I short of
rendering the,~ as preparati~ns o~betel nuts. Further, it would be inadvisable and inappropriate to
approach the issue of class1ficat1on of the said five goods solely with the prism of the positive
nature of Supplementary Note 2 to Chapter 21.

~ I

(1~
r. \ , ' }.
 . h . been sought I wish
r •
· non which advance ru Img as
oceed to an swe r the queSlto . • ·
'
f ection 28·
I 6. Before pr1 . . f the legal construct and specific prov1s1ons o s
to clarify that on careful co9n6s ictt1on tthe view that the task before me as the C ustoms Authority
(I ) fthc Customs Act, I , am O • • f d 51-·mply based
1 0 be to pass rulings on questions of class1ficatton o goo s
for Advance Rulings can no1 . ·1 d. ly acknowledge the persuasive value of the same. I
. ling of AAR even as rea I d
on the prev'.oushru .· ·ficance .of the contention made by the learned advocate regarding the nee
a Iso recognize
. t ef,signi 1
dvance rulings on classification matters, and the piquant s1tuat10n t a may
• • h t
fo~ cons1stenrtc·y ol acustoms station in the event of different orders by AAR and CAAR. In this
arise at a pa ,cu ar
.
. 1· h
•v,·ng at my ruling J refer to the judgments relied upon by the app tcant, ot er
regard' m arn , . . r
judgments referred to in this order, recent ruling of the Customs Authority for Advan~e Ru mgs,
Mumbai Ruling No. CAAR/Mum/ ARC/ l/2021 dated I 5.03.2021 m the cas~ rel_atmg to M/s
samreen International Pvt. Ltd, Chennai, other similar rulings, and my own ruling m the case of
Mis Star Spices and other similar rulings.
17. To answer the posed question, I consider the four goods, namely A Pl supari, Chikni supari,
unflavoured supari and boiled supari together. In these cases, one set of processes are found to be
intended for cleaning; the second set for enhancing preservation; and third set for enhancing
a_p~µU1ce or presentation. Addition of starch wouJd be included under such process. I find that
these processes are clearly covered by the Chapter Note 3 to Chapter 8. I also note that during the
personal hearing, the learned advocate requested to consider the distinction arising out of moderate
and he:avy 'boiling. In this regard, it is also submitted in the application that with the process of
boi'ling, betel nut loses the character of being fresh & dried nut therefore the item will not be
covered under Chapter 8. I find that 'in the instant case, betel nuts after being boiled are dried; and
this fact per se would not exclude the end-products from the scope of "dried nuts". Further, it is
equally obvious to me that boiling or mere addition of.certain additives for the limited purpose of
enhancing preservation or appearance or ease of co.nsumption per•se does not result in obtaining a
preparation of betel nut. Speaking more generally, in view of the design of the Schedule to the
CTA, HSN and plethora of judgements, besides common understanding and parlance, every
irreversible process does not result in obtaining a new product wit h a distinct classification even
at the eight or ten-cUgit level; and every process does not result in coming into being of a
"preparation ofthe raw mat~rial". Therefore, I conclude that the processes to which raw betel nuts
have been subjected to obtain API supari, Chikni supari, unflavoured supari and boiled supari are
squarely in the nature of processes referred to in the Chapter Note 3 to Chapter 8 and HSN Note.
Therefore, at the end of the said processes, the betel nuts retain the character of betel nut and do
not qualify to be considered as "preparations" of betel nut, which is sine qua non for a goQd to be
classifiable under Chapter 21. In this regard, l have carefully considered the submission and case
law cited by Shri Arora (para 4.1 above refers) and find that the kernel of the said decision does
not come of the aid of the applicant' s contention, inasmuch as it highlights different classification
for hormones and hormone-based contraceptives, the latter being considered a '' preparation'' .
 18. Jn the case of fl
special fl • avoured supari th .
avounng agents would ' e question to be answered is whether the addition of
under Chapter 21. ln thi·s re nd er the betel nuts into preparations of betel nuts. classifiable
. · regard th · -
of M/s Crane Betel N ' eJudgment of the Hon'ble Supreme Court of rndia in the case
Laminators Pvt Ltd ut Powder Works and of the CESTAT, Chennai in the case of Mis Azam
nut into sm ·: · [ where scented betel nut was being manufactured by cracking of dried betel
and fl ·
11 pieces, ao d thereafter, gently heating it with addition of vanaspati oil, sweetening
. avourmg agents and marketed in small pouches as Nizam Pakku (in Tamil)/Betel Nut (in
E ng l ish) the Hon' bl CESl' . .
O . ' . e AT held the resultant product classtfiable under sub-heading
8029019 of Central Excise Tariff and not under 21069030 as supari for period after 07.07.2009 J
are relevant. Put simply, these decisions clearly imply that addition of flavouring agents do not
change the character of the good, meaning in the present case betel nut would continue to remain
betel nut and not become preparation of betel nut.

19. In view of the aforesaid discussions, J have reached the conclusion that all the five goods
placed before me for consideration, i.e., APJ supari, chikni supari, boiled supari, unflavoured supari,
and flavoured supari , merit class1fication under Chapter 8 of the first Schedule to the Customs Tariff
Act, and more precisely, under the heading 0802. This is so in view of the fact that the processes to
which raw green fresh betel nuts have been subjected to obtain the said five goods are squarely in the
nature of processes mentioned in Note 3 to Chapter 8, and have not materially changed the essential
character of betel nuts, as held by the Hon 'ble Supreme Court in the M/s Crane Betel Nuts case. Further,
the said five goods are not classifiable under sub-heading 2 l069030f as contended by the applicant,
since they have not attained the character of "preparations" of betel nut, which is sine qua non for a
.......... .
good to.be so cons·idered.

2Q. I rule accordingly as regards classification and applicability of exemption notification.

Date: 31.05.2021

(Vijay Singh Chauhan)

Customs Authority fo.r Advance Rulings, New Delhi
 Dated: 3 t .05.2021
C. No. Vlll/(CAAR)/Delhi/Naman Agri/05/2021

This copy is certified to be a true copy of the ruling and is sent to: -

1. Mis Naman Agri lmpex Private Ltd. , E-4/23A, Model Town- 1, New Delhi-l 10009
2. Principal Commissioner of Customs, NS-I, .INCH, Nhava Sheva, Tat-Uran,
District- Raigad, Maharashtra-400707 .
3. Principal Commissioner of Customs, (Preventive), (CPC), 55-17-3, C- I 4 , 2"" Road, lndastnal
Estate, Auto Nagar, Vijayawada-520007 (A.P.)
4. Commissioner of Customs, O/o the Pr. Commissioner of Customs, Custom House, Mundra,
58, Port User Building, Mundra Port, Mundra, Kutch , Gujarat-370421
5. Customs Authority for Advance Rulings, Mumbai, New Custom House, Ballard Estate,
Mumbai-40000 l
6. The Principal Chief Commissioner of Customs, Delhi Customs Zone, New Custom House,
IGI Airport Complex, New Delhi-110037
7. The Chief Commissioner (AR), Customs Excise & Service Tax Appellate Tribunal
(CESTAT), West Block-2, Wing-2, R.K. Puram, New Dethi-110066
8. The Member (L & J), CBIC. North Block, New Delhi
9. Guard file

(A.K.Sapra)
Secretary ,
Customs Authority for Advance Rulings, New Delhi

-~ f.cr Mr..r,tt r.

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