Moisture and Ash Content Not Tested Properly for Areca Nuts’ Raw or Roasted Classification: Madras HC Remands Matter to Customs Commissioner [Read Order]
The essential classification parameters moisture and ash content were not tested properly and that the analysis was done in a non-accredited lab, rendering it unsustainable.
![Moisture and Ash Content Not Tested Properly for Areca Nuts’ Raw or Roasted Classification: Madras HC Remands Matter to Customs Commissioner [Read Order]](https://images.taxscan.in/h-upload/2025/06/13/2043785-madras-hc-areca-nuts-raw-roasted-customs-commissioner-taxscan.webp "Moisture and Ash Content Not Tested Properly for Areca Nuts’ Raw or Roasted Classification: Madras HC Remands Matter to Customs Commissioner [Read Order]")
The Madurai bench of Madras High Court has remanded the matter involving the import of areca nuts back to the Customs Commissioner for fresh consideration. The Court found serious lapses in the testing procedures and methodology adopted to determine whether the imported areca nuts were in raw or roasted form, an important issue for tariff classification and the applicable...
The Madurai bench of Madras High Court has remanded the matter involving the import of areca nuts back to the Customs Commissioner for fresh consideration. The Court found serious lapses in the testing procedures and methodology adopted to determine whether the imported areca nuts were in raw or roasted form, an important issue for tariff classification and the applicable customs duty.
The petitioner, Shahnaz Commodities, had imported roasted areca nuts. A core point of contention in the proceedings was the scientific determination of whether the areca nuts were roasted. The classification hinges on specific physical parameters most importantly, the moisture and ash content.
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In the instant case, the test report produced by the Customs Department, issued by the Central Revenues Control Laboratory (CRCL), lacked critical data on parameters of moisture and ash content.
The petitioner’s counsel cited the case of First Bench of this Court in W.A.No.3647 & 3648 of 2024 dated 04.03.2025, wherein it has held that “if the moisture content is below 10% and imported in terms of advance ruling that has attained finality, then there is no reason to state that the imported item is raw areca nut. In the light of the aforesaid judgment, the moisture content reported in the impugned ICAR-CPCRI test report ranges from 4.15% to 8.12% which reveals that the goods under seizure covered under seven bills of entry, are undoubtedly roasted betel nuts only.”
Justice Vivek Kumar Singh observed that such a vague and unsubstantiated conclusion could not form a legally sustainable basis for reclassification. The Court also noted that the test was conducted in a non-NABL (National Accreditation Board for Testing and Calibration Laboratories) accredited laboratory, further weakening the evidentiary value of the report.
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The Court found that the essential classification parameters moisture and ash content were not tested properly and that the analysis was done in a non-accredited lab, rendering it unsustainable. Additionally, it pointed out that the excessive detention delay was inflicting undue hardship.
Accordingly it quashed the customs detention, seizure, and summons orders against Shahnaz Commodities Regarding imported areca nuts. The same was remitted back to the Commissioner of Customs, Tutucorin for a fresh consideration.
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