Ayurvedic medicament classification turns on therapeutic value, recognised texts, and drug-control licensing for hair treatment products.

Classification of Rootz Oil turned on whether it was a cosmetic hair oil or an Ayurvedic medicament. The product was manufactured under a drug-control licence, used ingredients and herbs from recognised Ayurvedic texts, and was supported by clinical material and affidavits showing therapeutic use for hair and scalp ailments such as alopecia, dandruff, graying of hair and itching. Applying the principle that manufacture in accordance with authoritative Ayurvedic books and therapeutic or prophylactic value are material to medicament classification, the product was treated as an Ayurvedic medicine rather than merely a hair oil, and the Revenue's challenge failed.

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Issues: Whether Rootz Oil was classifiable as Hair Oil under sub-heading 3305.99 or as Ayurvedic medicine under sub-heading 3003.39.

Analysis: The product was manufactured under a drug-control licence, used ingredients and herbs specified in recognised Ayurvedic texts, and was supported by certificates, affidavits, and clinical material indicating use for treating hair and scalp ailments such as alopecia, dandruff, graying of hair, itching of the scalp, and improving blood circulation to hair follicles. The reasoning followed the Larger Bench view that manufacture in accordance with authoritative Ayurvedic books and under a drug-control licence supports classification as an Ayurvedic medicine, and also relied on the principle that therapeutic and prophylactic value is material to determining whether the product is a medicament.

Conclusion: Rootz Oil was held to be an Ayurvedic medicine and not merely Hair Oil, and the Revenue's appeal failed.

Ratio Decidendi: A product manufactured with ingredients from recognised Ayurvedic texts, under a drug-control licence, and shown to possess therapeutic and prophylactic value for treating ailments is classifiable as an Ayurvedic medicament rather than as a cosmetic or hair oil.

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