Role of HSN explanatory notes

HSN Explanatory Notes provide official international guidance on the HSN. They help explain the scope and meaning of tariff headings. Their use depends on alignment with the domestic tariff schedule. Where the domestic heading and HSN entry are aligned, the Notes guide interpretation. The judgment found the competing headings aligned with their HSN counterparts. No express statutory departure from the HSN was shown in this case. Where domestic wording differs, HSN guidance cannot displace that wording. Courts must check alignment before relying on the Explanatory Notes. Commissioner of Customs (Import) v. M/s Welkin Foods | 2026 INSC 19