The Gujarat High Court ruled that maize/corn starch is entitled to duty-free import benefits under SION Entry E22 as it is an immediate input in liquid glucose production through hydrolysis.
Starch Recognised as Qualifying Input for DFIA Benefits
The Gujarat High Court has held that imported maize or corn starch qualifies for duty-free import under the Duty-Free Import Authorisation (DFIA) scheme based on Standard Input-Output Norm (SION) Entry E22, which pertains to the manufacture of liquid glucose. The court determined that starch functions as the immediate and principal input in the hydrolysis process for producing liquid glucose, thereby satisfying the eligibility criteria under the notified SION.
The petitioner, a manufacturer of liquid glucose, had sought to import maize/corn starch without payment of customs duty under the DFIA scheme. The contention was that since SION Entry E22 expressly lists starch as an input for glucose manufacturing, its import should attract duty-free treatment. The Revenue opposed, arguing that the product derived was not covered or that the starch used was not directly linked. The Court rejected this view, emphasizing that the production process involves conversion of starch into glucose through enzymatic hydrolysis, a well-recognized industrial method.
Sachin K. Shah, J.: 'The input of starch has been specifically recognised in SION Entry E22 as the key raw material for manufacturing liquid glucose. Its importation, therefore, squarely falls within the purview of duty-free benefit.'
This decision reinforces the importance of technological accuracy in interpreting SIONs and supports industries reliant on imported raw materials for value-added exports. Practitioners should ensure proper documentation linking inputs to notified SION entries, especially in chemical and food processing sectors. The ruling may have implications for similar input-based DFIA claims involving bioconversion processes.
