Heena paste exemption applies where only a liquid medium is added and no active cosmetic ingredient is mixed.

Heena powder converted into paste with clove oil or another liquid remained eligible for exemption under the relevant Chapter 33 notification because the entry covered heena powder or paste not mixed with other ingredients. The operative distinction was between a mere liquid medium used to make the product marketable and usable, and the addition of active cosmetic or dye ingredients; only the former was present on the facts. As no active ingredient was added, the exemption condition was satisfied and the Revenue's challenge failed, with the finding in favour of the assessee upheld.

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Issues: Whether heena powder transformed into heena paste with clove oil or similar liquid, without addition of any active ingredient, was eligible for exemption under Sl. No. 134 of Notification No. 12/2013-C.E. dated 01.03.2013.

Analysis: The exemption entry for heena powder or paste under Chapter 33 was restricted to products not mixed with any other ingredients. The Board's clarification on the parallel exemption entry indicated that the benefit remained available where a liquid was used only as a medium to convert heena powder into paste, while products containing added cosmetic or dye ingredients were excluded. On the facts, the only substance used was clove oil or liquid to make the paste marketable and usable later, and no other active ingredient was shown to have been added. The factual basis therefore satisfied the condition of the exemption.

Conclusion: The exemption was applicable and the Revenue's challenge failed. The finding in favour of the respondent was upheld and the appeal was dismissed.

Ratio Decidendi: A heena paste remains within the exemption where the only addition is a liquid used as a medium to convert powder into paste and no active or cosmetic ingredient is added.

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