In Brief
The Supreme Court dismissed appeals by the Commissioner of Customs challenging the tariff classification of dried pomegranate seeds ('anardana'). The Revenue sought to classify anardana under Heading 0813 (dried fruits) attracting 30% duty, while importers classified it under Heading 1209 (seeds) at 5% duty. The Court held that anardana is derived from wild pomegranate, not the edible pomegranate fruit, and is used as a culinary acidulant and in Ayurvedic medicine. The Revenue bore the burden to prove the correct classification through evidence, which it failed to do. The Import Policy explicitly included pomegranate seeds under Heading 1209.99, supporting the importers' classification. The Court noted that anardana is predominantly exported from India as spices or medicaments, not dried fruit, and recommended the Revenue adopt a clear policy decision to avoid future litigation.
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