Classification of hair oil turns on essential character; anti-dandruff benefit does not change perfumed hair oil classification.

Hair oils containing coconut oil, perfume and other ingredients were held to retain their essential character as perfumed hair oil under Heading 3305.10. The presence of anti-dandruff or dandruff-eradicating features was treated as only a secondary function and did not alter the principal nature of the goods. Classification was determined by composition, use, common understanding of the product and the relevant tariff chapter notes. On that basis, the Revenue's claim for Heading 3305.99 was rejected and the assessee's classification under Heading 3305.10 was accepted.

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Issues: Whether the products described as hair oils were classifiable under Heading 3305.10 as perfumed hair oil or under Heading 3305.99 as claimed by the Revenue.

Analysis: The products contained coconut oil with perfume and other ingredients, and their essential identity remained that of perfumed hair oil. The additional anti-dandruff or dandruff-eradicating feature was only a secondary function and did not change the principal character of the goods. The classification had to be determined on the basis of the composition, the use, the common understanding of the product, and the relevant chapter notes under the tariff, which supported the earlier tribunal view on similar goods.

Conclusion: The products were correctly classifiable under Heading 3305.10 as perfumed hair oil and not under Heading 3305.99; the assessee succeeded.

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