Classification of medicated hair oil turns on dominant use and essential character, not claimed medicinal properties.

A preparation used as hair oil is not excluded from classification as a toilet article merely because it claims medicinal properties. The relevant test is the essential character of the commodity, including whether it is more complex than crude natural oils and whether its dominant use is for toilet purposes. Applying that approach, Medicated Brahmi Oil was treated as a toilet article within item 11 of the amended Schedule I of the Sales Tax Act and therefore taxable accordingly.

---

---

Issues: Whether the preparation known as Medicated Brahmi Oil was a toilet article within item 11 of the amended Schedule I of the Sales Tax Act.

Analysis: A commodity used as hair oil is not necessarily a toilet article. The relevant considerations were whether the preparation was more complex than crude natural oils and whether its object of use was primarily to serve toilet purposes. On those criteria, the preparation was treated as a toilet article, notwithstanding its asserted medicinal properties.

Conclusion: The commodity fell within item 11 of the amended Schedule I of the Sales Tax Act and was taxable as a toilet article.

Ratio Decidendi: Classification depends on the essential character and dominant use of the commodity, and not merely on claimed medicinal properties.

---