Indirect Tax Laws · Types of Duty

Duty on Goods with Articles at Different Rates (Section 19, Customs Act, 1962)

Updated 5 October 2026 · Fact-checked

Section 19 of the Customs Act, 1962 fixes the duty on goods that combine parts or articles with different rates. A mixture of materials or articles not separately specified in the tariff is charged at the rate of the part that yields the highest duty. Different articles that are separately specified are each charged at their own rate.

Understand Duty on Goods with Articles at Different Rates (Section 19)

A consignment is often not one clean item. Goods may be a mixture of materials, or a lot of different articles, each with a different rate of duty. The question is which rate applies. Section 19 answers this.

The section opens with the words Unless otherwise provided in the Customs Tariff Act, 1975 or any other law. So if those laws already give a specific treatment for the goods, follow that first. Do not claim that anything else overrides the section unless the question cites a specific provision.

The section has two limbs:

Mixture of two or more materials or articles, not separately specified in the tariff: the goods are charged at the rate applicable to that part which yields the highest duty. The whole goods bear that one rate.
Different articles that are separately specified in the tariff: each article is charged at its own rate.

The key test is the nature of the goods. Is it one thing made of a mixture of materials or articles with no tariff entry of its own for the mix? Or is it a set of distinct articles, each with its own tariff entry? The highest duty rule belongs to the first case only. Distinct, identifiable articles with separate values are not a mixture.

In an exam answer, state why the goods are a mixture not separately specified before you apply the highest duty rule. If you jump straight to the highest rate, you lose the reasoning marks.

The working is simple arithmetic. The skill is in reading the facts. Unless the question says otherwise, assume the rates given are the total rates to be applied on assessable value.

Key rules to remember

Opening words of section 19: Unless otherwise provided in the Customs Tariff Act, 1975 or any other law, the two limbs of section 19 apply; Check first whether the Tariff Act or another law gives a specific treatment of the goods.
Separately specified articles: Duty = Σ (Assessable value of each article × its own rate of duty); Use when the goods consist of different articles, each separately specified in the tariff.
Mixture not separately specified (highest duty rule): Duty = Total assessable value × rate of the part that yields the highest duty; Use for a mixture of materials or articles not separately specified. Applying each part's rate to the total value shows which part yields the highest duty.
Effect of the rule: Extra duty = Duty at highest rate − Σ (part value × own rate); A comparison figure for questions that ask for the effect of the rule. It is not a separate legal computation.

How to solve Duty on Goods with Articles at Different Rates (Section 19) questions

Use this method for any question on duty where goods combine parts or articles with different rates.

1List every article or part with its assessable value and its rate of duty.
2Check whether the Customs Tariff Act, 1975 or any other law gives a specific treatment of the goods. If the facts say so, follow it.
3Decide whether the goods are a mixture of materials or articles not separately specified in the tariff, or different articles that are separately specified. Write one line giving the reason.
4If they are separately specified articles, multiply each value by its own rate and add the results.
5If they are a mixture not separately specified, apply each part's rate to the total value. The part that yields the highest duty fixes the rate for the whole goods.
6Add any other levy only if the question gives it and asks for it. Otherwise state that you have computed the duty on the rates given.
7State the final duty clearly and give section 19 as the basis of your conclusion.

Quickest way: Two-question shortcut

When to use it: Use in the MCQ section or when a written answer needs a fast check.

Ask: is it one mixture with no separate tariff entry for its parts, or distinct articles each separately specified?
If it is a mixture, circle the highest rate in the question and multiply it by the total value.
If they are separate articles, compute article by article.
Check the answer: the highest rate duty can never be lower than the part-wise total.
Write the section number and the one-line reason in your answer.

Common mistakes in Duty on Goods with Articles at Different Rates (Section 19)

Applying the highest rate to separately specified articles
Students remember the highest rate rule and use it on every lot with different rates.
Fix: Apply it only to a mixture not separately specified. Charge separately specified articles at their own rates.
Using a simple average of the rates
A mixture suggests a blended rate.
Fix: The section never uses an average. It uses either each article's own rate or the rate of the part yielding the highest duty.
Applying the highest rate only to the part carrying it
Confusion with article-wise assessment.
Fix: Under the highest duty rule the rate applies to the whole goods, meaning the total assessable value.
Treating distinct articles with separate values as a mixture
The word 'mixed lot' in a question sounds like a mixture.
Fix: A mixture means materials or articles blended into one set of goods. Distinct identifiable articles with their own tariff entries are separately specified.
Ignoring the opening words of the section
Students treat section 19 as a standalone rule.
Fix: Begin with 'Unless otherwise provided in the Customs Tariff Act, 1975 or any other law'. Mention any specific provision given in the facts.
Using invoice value instead of assessable value
Rushing through the working.
Fix: Use the assessable value given in the question. If only an invoice price is given with freight or insurance, state your assumption.
Giving only the number with no reasoning
Students treat it as arithmetic.
Fix: Write provision, facts and conclusion. The reasoning earns marks even if the arithmetic slips.

Worked examples

Example 1

Madhav Traders imports goods that are a mixture of three materials, A, B and C, and the mixture is not separately specified in the tariff. The assessable values of the parts and the rates applicable to each material are: A ₹2,00,000 at 10%; B ₹1,50,000 at 20%; C ₹1,50,000 at 15%. No other law is stated to apply. Compute the duty payable under section 19 of the Customs Act, 1962, and show how much more it is than part-wise duty.

Show the solution

Total assessable value = ₹2,00,000 + ₹1,50,000 + ₹1,50,000 = ₹5,00,000.
The goods are a mixture of materials not separately specified in the tariff. So the part yielding the highest duty fixes the rate for the whole goods.
Duty if rate of A applied to the whole = ₹5,00,000 × 10% = ₹50,000.
Duty if rate of B applied to the whole = ₹5,00,000 × 20% = ₹1,00,000.
Duty if rate of C applied to the whole = ₹5,00,000 × 15% = ₹75,000.
The highest duty is ₹1,00,000, at the rate of B, 20%.
Part-wise duty for comparison = ₹20,000 + ₹30,000 + ₹22,500 = ₹72,500.
Extra duty because of the rule = ₹1,00,000 − ₹72,500 = ₹27,500.

Answer: Duty payable is ₹1,00,000 at 20% on the whole goods. This is ₹27,500 more than the part-wise figure of ₹72,500.

Example 2

Sundaram Exports Ltd. imports one consignment containing three different articles, each separately specified in the tariff with its own entry. Assessable values and rates: Article X ₹1,00,000 at 5%; Article Y ₹2,00,000 at 12%; Article Z ₹50,000 at 18%. The importer says the highest rate of 18% should apply to the whole consignment. Examine and compute the duty.

Show the solution

The articles are different and each is separately specified in the tariff, so each is charged at its own rate.
The highest duty rule is for a mixture not separately specified. It does not apply here, so the importer's view is incorrect.
Duty on X = ₹1,00,000 × 5% = ₹5,000.
Duty on Y = ₹2,00,000 × 12% = ₹24,000.
Duty on Z = ₹50,000 × 18% = ₹9,000.
Total duty = ₹5,000 + ₹24,000 + ₹9,000 = ₹38,000.

Answer: Duty payable is ₹38,000, charged article by article. The 18% rate applies only to Article Z, not to the whole consignment.

Exam tips

Always write the condition: mixture not separately specified, or separately specified articles. This is where marks are given.
In case-scenario MCQs, look for words such as 'mixture of materials' and 'not separately specified' as the trigger for the highest duty rule. A set of distinct articles with their own entries points to article-wise duty.
Show the comparison with part-wise duty if the question asks about the effect or the difference.
If the facts cite a provision of the Customs Tariff Act or another law on the goods, mention it, since section 19 opens with 'unless otherwise provided'.
Keep the answer short: provision, facts, working, conclusion.

Practice questions from Types of Duty

Duty on Goods with Articles at Different Rates (Section 19): frequently asked questions

What does section 19 of the Customs Act, 1962 deal with?

It deals with the duty on goods that are a mixture of materials or articles, or consist of different articles, liable to different rates. It tells you whether to charge the highest duty rate on the whole goods or each article at its own rate.

When is the highest rate of duty applied?

When the goods are a mixture of two or more materials or articles not separately specified in the tariff. The rate of the part that yields the highest duty is applied to the goods as a whole.

What if the articles are separately specified in the tariff?

Each article is charged at the rate applicable to it. The highest duty rule does not apply, and you add the duty on each article.

What does 'unless otherwise provided' mean in section 19?

The section opens with the words 'Unless otherwise provided in the Customs Tariff Act, 1975 or any other law'. If a specific provision in those laws covers the goods, that provision is followed. Cite the provision in your answer when the facts point to one.