Win for Adyar Ananda Bhavan: CESTAT Rules "Heat Wave Frying System" Classifies as Other Machinery, Not Kitchen Machines [Read Order]

The Chennai Bench of the Customs, Excise, and Service Tax Appellate Tribunal (CESTAT) ruled in favor of Adyar Ananda Bhavan Sweets & Snacks, holding that the imported “Namkeen System HWF 2412” qualifies as “other machinery” under CTH 84388020 and not as “kitchen machines” under CTH 84198120.

Adyar Ananda Bhavan imported a Heat Wave Frying System used for mass production of snacks and declared it under CTH 84388020. The customs authorities disputed the classification and reclassified it under CTH 84198120, demanding differential duty. The adjudicating authority concluded it was kitchen equipment due to its food-processing function and issued a demand.

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The importer appealed the decision, and the Commissioner (Appeals) reversed the classification, recognizing the machinery as an industrial-scale fryer. The department challenged this decision before CESTAT, arguing the machine fell under “other kitchen machines.”

The department claimed the fryer was used in food preparation, which generally falls under kitchen appliances. The appellate authority, after examining the product literature and its commercial application, observed that the machine was designed for industrial-level food production and not for kitchen-scale use.

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The two-member bench comprising P. Dinesha ( Judicial Member ) and M. Ajit Kumar (Technical Member) observed that the product catalogue and import documents confirmed that the equipment was an automated fryer designed for industrial-scale production of snacks. The Order-in-Appeal had correctly referenced the literature, which made it clear that the machine was not intended for kitchen use but for large-scale commercial food processing.

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The tribunal observed that CTH 84198110 specifically covers “fryers” and CTH 84198120 covers “other kitchen machines.” The tribunal found that neither of these was appropriate given the scale and industrial purpose of the equipment. Instead, CTH 84388020, which covers “other machinery,” was deemed accurate.

Finding no merit in the department’s appeal, the tribunal upheld the Commissioner (Appeals)'s decision and dismissed the case. The ruling clarifies the classification of large-scale food processing machinery and reinforces the principle that tariff classification must reflect the actual use and scale of the imported equipment.

To Read the full text of the Order CLICK HERE

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