In Brief
The Supreme Court resolved a tariff classification dispute concerning dried pomegranate seeds ('anardana'). The Revenue claimed they should be taxed as dried fruits under Heading 0813 (attracting 30% duty), while importers argued they belonged under Heading 1209 seeds (attracting 5% duty). The Court held that 'anardana' is a product of wild pomegranate (daru), distinct from edible fresh pomegranates, and does not fall under Chapter 8 (edible fruits). It is classifiable under Heading 1209.99 (seeds for sowing), as confirmed by Export/Import Policy, expert evidence, and Harmonised System exclusions. The Revenue bore the burden of proof when challenging the assessee's classification but failed to discharge it. Appeals dismissing differential duties were upheld.
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