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Supreme Court of India 2023-10-20 partly_allowed

COMMR. OF CEN. EXC. AHMEDABAD vs M/S URMIN PRODUCTS P. LTD. AND OTHERS

Bench: 2 — S. Ravindra Bhat, Aravind Kumar

In Brief

This consolidated judgment addresses the classification of chewing tobacco and zarda/jarda scented tobacco under the Central Excise Tariff. Seven separate appeals involving competing claims about product classification were heard together. The Court upheld the revenue's demand in cases (Urmin, Kaipan Masala) where assesses deliberately changed classification to evade higher duty after tariff entry realignment. However, it dismissed appeals where the revenue failed to produce sufficient evidence of misclassification or where the Department itself had previously approved the assessee's classification (Flakes-n-Flavourz, Tej Ram Dharam Paul, Som Pan, Tara Chand). The Court clarified that under CTPM Rules, the Prescribed Authority has jurisdiction to determine correct classification when examining production capacity declarations, but the burden to prove misclassification remains with Revenue. Willful misstatement requires deliberate intent to evade duty, not mere discrepancies in description.

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Central Excise Classification of Goods Tariff Entry Chewing Tobacco and Zarda Scented Tobacco Section 11A Extended Period of Limitation Willful Misstatement Suppression of Facts Fiscal Law Administrative Law Rule 6 CTPM Rules

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