SC Upholds No Reclassification of Mineral Spirit as HSD

Centax Editorial Board

April 4, 2026

• 2 min. read

Case Details: Additional Director General (Adjudication) vs. N.V. Rambabu (2026) 41 Centax 8 (S.C.)

Judiciary and Counsel Details

Sanjay Kumar & K. Vinod Chandran, JJ.
S/Shri N. Venkataraman, A.S.G., V.C. Bharathi, Nasadiya Singh, Bhakti Vardhan Singh, Raman Yadav, Ms Divya Jyoti Singh, Advocates & Gurmeet Singh Makker, AOR, for the Petitioner.

Facts of the Case

Proceedings were initiated against the appellant-importer based on intelligence gathered by the Directorate of Revenue Intelligence indicating alleged misdeclaration of imported goods as Mineral Spirit under Customs Tariff Item 2710 19 90, whereas the department alleged that the goods were in fact High Speed Diesel classifiable under Tariff Item 2710 19 30. Samples of the imported petroleum product were tested at the Customs Laboratory, which conducted analysis on limited parameters and issued a report suggesting that the goods were other than Mineral Spirit and could be considered as diesel oil. Relying on such test report, the adjudicating authority reclassified the goods and confirmed the demand. On appeal, the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) held that the test report was incomplete as it did not examine all parameters prescribed under the applicable BIS standards and statutory notes, and therefore set aside the reclassification. Aggrieved by the said order, the department preferred an appeal before the Supreme Court, and the matter was accordingly placed before the Hon’ble Supreme Court.

Supreme Court Held

The Hon’ble Supreme Court held that in view of its earlier judgment in a connected matter, no ground was made out to interfere with the impugned order passed by the tribunal. It observed that the issue stood concluded by the dismissal of the civil appeal in the case relied upon, and the same reasoning applied to the present matter. The Court, therefore, declined to re-examine the findings recorded by the tribunal on classification. Consequently, the appeals filed by the department were dismissed. Pending applications, if any, were also disposed of.