Ayurvedic medicament classification turns on conformity with authoritative formulas and names in recognised texts.

Ayurvedic products qualify for classification under sub-heading 3003.31 where they are manufactured exclusively according to formulae in authoritative Ayurvedic books specified in the First Schedule to the Drugs and Cosmetics Act, 1940, and are sold under the names used in those texts. The record showed that both Shankha Pushpi and Janam Ghunti appeared in the relevant authoritative books, and the preparation of each matched the prescribed formula, including equal-quantity ingredients where no quantity was specified and jaggery added q.s. No contrary expert opinion or rebuttal evidence was produced to displace the assessees' materials. They were therefore classifiable under sub-heading 3003.31 and not under 3003.39.

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Issues: Whether the products "Shankha Pushpi" and "Janam Ghunti" were classifiable as medicaments manufactured exclusively in accordance with the formulae described in authoritative Ayurvedic books under sub-heading 3003.31, or as other medicaments under sub-heading 3003.39.

Analysis: The relevant tariff entry covered medicaments used in Ayurvedic systems and granted the specific classification under sub-heading 3003.31 where the goods were manufactured exclusively according to formulae described in authoritative books specified in the First Schedule to the Drugs and Cosmetics Act, 1940 and sold under the names specified in those books. The finding that both products found place in the relevant authoritative texts had attained finality. On the remaining requirement, the record showed that the ingredients for "Janam Ghunti" were used in equal quantity where no quantity was specified in the text, with jaggery added as quantity sufficient, and that "Shankhapushpi Syrup" was prepared in accordance with the formula from the authoritative book. No contrary expert opinion or material was produced by the Revenue to displace the appellants' evidence.

Conclusion: Both products were held classifiable under sub-heading 3003.31 and not under sub-heading 3003.39.

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