Imported Exxsol Hexane Will Attract Lower Customs Duty Of 2.5%: Supreme Court

The Supreme Court has held that the imported Exxsol hexane will attract a lower customs duty of 2.5%. The bench of Justice Aravind Kumar andJustice Prasanna B. Varale has observed that has upheld the decision of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) in favour of M/s Reliance Industries Ltd., holding that imported “n-Hexane” or “Exxsol Hexane” is classifiable as a separate chemically defined hydrocarbon compound under Chapter 29 and not as petroleum oil or motor spirit under Chapter 27 of the Customs Tariff framework. The dispute arose from the import of n-Hexane by Reliance Industries, where the company had declared the goods under Customs Tariff Heading (CTH) 2901.10 and Central Excise Tariff Heading (CETH) 2901.90, treating the product as a saturated acyclic hydrocarbon existing in pure commercial form. However, customs authorities disputed the classification and sought to classify the imported product under CTH 2710.00 and CETH 2710.12 as petroleum oil and motor spirit. The department relied heavily on a chemical test report issued by SGS Redwood Services which noted that the imported material had a distillation range between approximately 63°C and 70°C and a flash point below 25°C. Customs authorities argued that these characteristics indicated the imported substance was a mixture of hydrocarbons and therefore should be treated as motor spirit under Chapter 27. The Supreme Court, however, undertook a detailed examination of the chemical nature and structure of n-Hexane. The Court explained that n-Hexane is a saturated acyclic hydrocarbon having the chemical formula C6H14 with a linear molecular structure. It observed that despite the existence of multiple isomers of Hexane, n-Hexane itself possesses a distinct and definitive structural arrangement that differentiates it from other variants. The Bench also extensively analysed the Harmonized System of Nomenclature (HSN) explanatory notes and reiterated that such notes are an internationally accepted guide in resolving tariff classification disputes. The Court emphasized that where competing classifications exist, the heading giving the most specific description should prevail over a more general heading. Referring to HSN provisions, the Court noted that Chapter 29 specifically includes Hexanes among saturated acyclic hydrocarbons, while Chapter 27 generally concerns petroleum oils and related products. It held that the specific inclusion of Hexane under Chapter 29 made it the more appropriate classification. The judgment also dealt with the department’s argument that impurities in the imported product converted it into a mixture excluded from Chapter 29. Rejecting this contention, the Court observed that minor impurities naturally resulting from the manufacturing process do not alter the essential character of a chemically defined compound. It clarified that impurities resulting from production processes do not necessarily transform a product into a different commercial substance. The Court observed that for a product to qualify as “motor spirit” under Chapter 27, three conditions had to be fulfilled: it should be a hydrocarbon oil, possess a flash point below 25°C, and be suitable for use as fuel in spark ignition engines. The Revenue had only established the flash-point requirement and failed to produce evidence showing that the imported product was actually suitable for use as fuel in spark ignition engines. The Supreme Court held that the burden of proving tariff classification rests upon the Revenue and mere assertions without sufficient evidence cannot sustain a classification claim. The Court reiterated that where an article reasonably falls under a specific tariff heading, it should not be pushed into a more general category. The Court affirmed that n-Hexane is classifiable under Chapter 29 as a separate chemically defined compound and dismissed the Revenue’s challenge against Reliance Industries. Case Details Case Title: Commissioner Of Customs Versus M/S Reliance Industries Limited Citation: JURISHOUR-1387-SC-2026 Case No.: CIVIL APPEAL NO. 569 OF 2012 Date: 25/05/2026 Click Here To Read Order

Imported Exxsol Hexane Will Attract Lower Customs Duty Of 2.5%: Supreme Court

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