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Issues: Whether the products 'Nenmeni Snana Choornam' and 'Ousadha Thali' are classifiable as Ayurvedic medicaments under Chapter heading 3003.30 of the Central Excise Tariff Act, 1985, or as cosmetics/consumer products under the competing headings.
Analysis: Classification depended on whether the goods answered the common parlance understanding of Ayurvedic medicines and whether their ingredients were found in authoritative Ayurvedic texts. The Tribunal relied on the departmental circular recognising these tests and held that manufacture strictly in accordance with a classical formula was not essential, since even patent or proprietary Ayurvedic medicaments can fall under the same tariff entry. The products were supported by a Drug Controller certificate describing them as Ayurvedic products, and there was no contrary expert opinion on record. The Tribunal also held that the distinction between an Ayurvedic product and an Ayurvedic medicine was not material for tariff classification where the goods were products of Ayurveda with Ayurvedic ingredients.
Conclusion: The products were held to be correctly classifiable as Ayurvedic medicaments under Chapter heading 3003.30, and not as cosmetics or hair oil.
Final Conclusion: The appeal succeeded because the disputed goods were treated as Ayurvedic medicaments entitled to the beneficial tariff classification.
Ratio Decidendi: A product having Ayurvedic ingredients and recognised by supporting expert material may be classified as an Ayurvedic medicament under Chapter heading 3003.30 even if it is a patent or proprietary preparation and not manufactured strictly according to a classical Ayurvedic text.