JUDGMENT

Vibhu Bakhru, J. These appeals, filed under Section 28KA of the Customs Act, 1962 (hereafter `the Customs Act'), involve a common question regarding the classification of "Boiled Supari" under the Customs Tariff Act, 1975 (hereafter `the Customs Tariff Act'). The orders impugned in these appeals are also somewhat similarly worded. Thus, the present appeals were heard together and are being disposed of by this common order.

2. M/s Great Nuts Impex Pvt. Ltd. (Appellant in CUSAA 17/2022) had filed an application dated 23.09.2020 before the Customs Authority of Advanced Ruling (hereafter `CAAR') seeking an advance ruling under Section 28H of the Customs Act regarding classification of the goods proposed to be imported. M/s Great Nuts Impex Pvt. Ltd. proposed to import into India a preparation of Betal Nuts known as `Boiled Supari' packed in consumer packing and bulk packing. The proposed items included, (i) API Supari; (ii) Chikni Supari; (iii) Unflavoured Supari; (iv) Flavoured Supari; and (v) Boiled and Cut Supari. The said appellant proposed that the afore-mentioned goods be classified as "Betel nut product known as `Supari'" under sub-heading 2106 90 30 in Chapter 21 of the First Schedule to the Customs Tariff Act (the First Schedule to the Customs Tariff Act is hereafter referred to as `Customs Tariff') and sought a ruling on the following question:

"Whether the goods sought to be imported is preparation of betel nut commonly known as Supari as described herein above, whether or not containing added ingredients such as food starch, spices, mulethi, menthol (flavors), perfume etc. Though not containing lime or katha (catechu) or tobacco and will the resultant product be classifiable under Chapter/heading 2106 90 30 as Food Preparation."

3. According to M/s Great Nuts Impex Pvt. Ltd., the said goods were not classifiable under Chapter 8 of the Customs Tariff as Areca nuts (heading 0802 80). M/s Great Nuts Impex Pvt. Ltd.'s contention was not accepted and by an order dated 20.05.2021 (Ruling No.CAAR/DEL/GREAT NUTS/05/2021), which is impugned in CUSAA 17/2022, the CAAR ruled to the contrary. The CAAR found that the goods in question were classifiable under heading 0802 and not under sub-heading 2106 90 30 as contended by M/s Great Nuts Impex Pvt. Ltd.

4. M/s The Nuts Co. (Appellant in CUSSA 18/2022) had also filed a similar application before the CAAR proposing to import goods similar to those as proposed to be imported by M/s Great Nuts Impex Pvt. Ltd. in its application. M/s The Nuts Co. also sought a ruling on the question, which was identically worded as the question framed by M/s Great Nuts Impex Pvt. Ltd. in its application. M/s Great Nuts Impex Pvt. Ltd. and M/s The Nuts Co. are hereafter, for the sake of brevity, collectively referred to as `the appellants'.

5. The said application filed by M/s The Nuts Co. also met the same fate as the application of M/s Great Nuts Impex Pvt. Ltd. and was disposed of by a ruling dated 04.06.2021 (Ruling No. CAAR/DEL/The Nut/10/2021), in similar terms as the ruling dated 20.05.2021. The CAAR, inter alia, relied upon the decision of Crane Betel Nut Powder Works v. Commissioner of Customs and Excise, Tirupathi & Anr., 2007(210) E.L.T. 171 to hold that the products in question, merit classification under Chapter 8 of the Customs Tariff.

6. The rulings dated 20.05.2021 and 04.06.2021 are hereafter referred to as `the impugned rulings'.

7. Before proceeding further, it would be relevant to refer to the goods as proposed to be imported by the appellants and the process of preparation. As noted above, both the appellants proposed to import "Boiled Supari packed in consumer packing and bulk packing". They claimed that the process of preparation of the various types of import items is as under:

"i) `API Supari': Following processes are conducted on raw green fresh betel nut: removing of large impurities by labourers, boiling in water for 6 hours, mixing food starch, drying, polishing a