Supreme Court Holds That Aluminium Mushroom Growing Racks Are ‘Aluminium Structures’ and Not ‘Parts of Agricultural Machinery’ for Customs Classification Purposes

Case Name: Commissioner of Customs (Import) v. M/s Welkin Foods
Citation: 2026 INSC 19
Date of Judgment/Order: 06 January 2026
Bench: Justice J.B. Pardiwala, R. Mahadevan

Held: The Supreme Court held that aluminium shelving systems imported for mushroom cultivation are classifiable as “aluminium structures” under Customs Tariff Item 76109010 and not as “parts” of agricultural machinery under CTI 84369900, as the goods do not possess the essential character of a machine or mechanical appliance and their end use or subsequent integration with other equipment cannot determine tariff classification contrary to the clear language of the tariff and the General Rules for Interpretation.

Summary: The dispute arose from the classification of aluminium mushroom growing racks imported by the respondent, who claimed classification under CTI 84369900 as parts of agricultural machinery, attracting nil duty. The customs authorities reclassified the goods under CTI 76109010 as aluminium structures, resulting in a demand of differential duty. While the adjudicating authority and the Commissioner (Appeals) upheld the reclassification, the CESTAT reversed the decision relying on end use, trade parlance, and integration of the racks with other mushroom cultivation equipment. The Supreme Court undertook an exhaustive analysis of the Customs Act, the Customs Tariff Act, the Harmonised System of Nomenclature, the General Rules for Interpretation, and prior jurisprudence on common parlance and end-use tests, and held that classification must primarily be determined by the terms of the tariff heading and the condition of the goods at the time of import. The Court found that the racks were static supporting structures lacking moving parts or mechanical function and therefore could not be treated as machines or parts thereof.

Decision: The appeal was allowed, the judgment of the CESTAT was set aside, the orders of the adjudicating authority and the Commissioner (Appeals) classifying the goods under CTI 76109010 were restored, the demand of differential customs duty with applicable interest was upheld, and all pending applications were disposed of.