Supreme Court Clarifies Customs Classification of Anardana (Dried Pomegranate Seeds) under the Customs Tariff Act, 1975

Aadrikaa Legal Services (ALS) – IDT Tax I Arbitration I Litigation

Date: 20.05.2026

Supreme Court Clarifies Customs Classification of Anardana (Dried Pomegranate Seeds) under the Customs Tariff Act, 1975

The Supreme Court of India recently delivered a significant judgment in the case of Commissioner of Customs and Central Excise, Amritsar vs. M/s D.L. Steels and others. The dispute centered on the correct customs classification and duty assessment for dried pomegranate seeds, commonly known as ‘anardana’, imported from Pakistan.

The Core Issue

The main question was whether anardana should be classified under:

• Heading 0813 (“Fruit, dried, other than that of headings 08.01 to 08.06”)—as argued by customs authorities, attracting a higher duty (30% plus cess), or
• Heading 1209 (“Seeds, fruit and spores, of a kind used for sowing”)—as claimed by the importers, attracting a lower duty (5% plus cess).

Case History

1. Initial Assessment: Customs authorities classified anardana under Heading 0813.40.90, imposed higher duty, and levied penalties.
2. Appeal by Importers: The Commissioner (Appeals) sided with the importers, holding that anardana is made from wild pomegranate not consumed as fresh fruit, and thus Heading 0810 (fresh fruit) and by extension 0813 (dried fruit) did not apply. The Import Policy also specifically allowed free import of pomegranate seeds under Heading 1209.99.90.
3. Revenue’s Appeal: The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) upheld the importers’ classification, referencing expert certificates and trade usage, and found no evidence that anardana is considered a dried fruit in trade parlance.
4. Supreme Court Appeal: The Revenue challenged these findings before the Supreme Court.

Supreme Court’s Analysis

• Interpretation Principles: The Court emphasized that words in taxing statutes should be interpreted in their common or trade parlance unless a special definition exists.
• Nature of Anardana: Evidence showed that anardana is made from wild pomegranate (“daru”), which is not consumed as fresh fruit but is dried for use as a spice or acidulant in cooking and Ayurvedic medicine.
• Classification Rules: The Court examined the Harmonised System of Nomenclature (HSN) and General Rules of Interpretation, noting that:
  • Heading 0813 covers dried fruits that, when fresh, are edible fruits classified under Headings 0807 to 0810.
  • Wild pomegranate used for anardana is not consumed as a fresh fruit and thus does not fit this category.
  • Heading 1209, supported by the Import Policy, specifically includes pomegranate seeds and allows their import without licensing restrictions.
• Trade Practice: The Court noted that most anardana exports from India are classified as spices or Ayurvedic medicaments, not as dried fruit.

The Verdict

The Supreme Court dismissed the Revenue’s appeals, confirming that anardana should be classified under Heading 1209.99.90 as seeds, not as dried fruit under Heading 0813.40.90. This means the importers, including D.L. Steels, prevailed.

Implications

• For Importers: The judgment clarifies that dried pomegranate seeds (anardana) attract a lower customs duty, reducing costs for importers.
• For Customs Authorities: The decision underscores the importance of trade usage and specific policy notes in classification disputes.
• For Trade and Industry: The ruling provides certainty and consistency in the treatment of anardana imports, aligning with both trade practice and government policy.

Conclusion

This Supreme Court decision is a landmark for importers of anardana and similar products, reinforcing the principle that classification should reflect trade understanding and specific policy guidance. The case also highlights the need for clear evidence and careful application of customs rules in classification disputes.

Connected Matter

CESTAT Delhi Ruled on Customs Duty and Classification of Imported Mobile Phone Parts

Source: Supreme Court

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