Ayurvedic medicament classification turns on therapeutic claims, while hair-care products without curative use remain cosmetics.

Products prepared from Ayurvedic ingredients are classifiable as medicaments under Chapter 30 when their composition, user perception and marketing show therapeutic or prophylactic claims for specific ailments; on that basis, Jyotishmathi Taila, Bhringamalaka Taila and Sukumara Taila were treated as Ayurvedic medicaments. A preparation that is promoted only for hair growth, without any curative or medicinal claim, retains the character of a cosmetic or toilet preparation under Chapter 33; Neelakeshaposhini was classified accordingly as a hair tonic/cosmetic product.

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Issues: Whether the four impugned products were classifiable as Ayurvedic medicaments under Chapter 30 or as cosmetic and toilet preparations under Chapter 33 of the Central Excise Tariff Act, 1985.

Analysis: The products had to be classified on the basis of their composition, user perception, and claimed therapeutic or prophylactic effect. Where the goods were prepared from ingredients found in Ayurvedic texts and were represented as having curative or preventive properties for specific ailments, they were not to be treated as mere cosmetics or toilet preparations. Applying this principle, Jyotishmathi Taila, Bhringamalaka Taila, and Sukumara Taila were found to have therapeutic claims and medicinal character. Neelakeshaposhini, however, was only claimed to promote hair growth and did not disclose any curative or medicinal use, so it retained the character of a hair tonic/cosmetic preparation.

Conclusion: Jyotishmathi Taila, Bhringamalaka Taila, and Sukumara Taila were correctly classifiable as Ayurvedic medicaments under Chapter 30, while Neelakeshaposhini was classifiable as a cosmetic and toilet preparation under Chapter 33.

Final Conclusion: The classification was upheld for three products and modified only for Neelakeshaposhini, with the result that the revenue challenge succeeded only in part.

Ratio Decidendi: A product prepared from Ayurvedic ingredients and marketed with therapeutic or prophylactic claims is classifiable as an Ayurvedic medicament, but a preparation with only cosmetic or hair-care use and no curative claim remains a cosmetic or toilet preparation.

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