Ayurvedic medicament classification turns on Ayurvedic ingredients, authoritative formulations, and medicinal character rather than cosmetic or supplement labels.

Products manufactured exclusively from Ayurvedic ingredients in accordance with authoritative Ayurvedic formulations were treated as Ayurvedic medicaments rather than cosmetics or food supplements. Mahachandanadi Tel was classified under Heading 3003.31 because it was specifically listed in the Ayurvedic pharmacopoeia and followed recognised medicinal formulae, while its therapeutic character alone was not decisive. Castor (Erand) Oil was also classified under Heading 3003.31 because it was a medicament made from Ayurvedic ingredients, making the alternative heading inapplicable. Stimulex Capsules/Tablet was likewise treated as a medicinal preparation under Heading 3003.39, not a food supplement under Heading 2108.99.

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Issues: (i) whether Mahachandanadi Tel was classifiable as an Ayurvedic medicament under Heading 3003.31 or as a cosmetic under Heading 3304.00; (ii) whether Castor (Erand) Oil was classifiable as an Ayurvedic medicament under Heading 3003.31 or under Heading 3003.20/3003.39 as adopted by the Revenue; and (iii) whether Stimulex Capsules/Tablet was classifiable as an Ayurvedic medicament under Heading 3003.39 or as a food supplement under Heading 2108.99.

Issue (i): whether Mahachandanadi Tel was classifiable as an Ayurvedic medicament under Heading 3003.31 or as a cosmetic under Heading 3304.00

Analysis: The product was found to be specifically mentioned in the Ayurvedic pharmacopoeia and to be made exclusively from Ayurvedic ingredients in accordance with authoritative Ayurvedic formulae. Its character was held to be comparable to an earlier product already accepted as classifiable under Heading 30.03. The fact that a product may have some therapeutic value does not by itself determine classification, but the decisive feature here was its Ayurvedic medicinal composition and formulation.

Conclusion: Mahachandanadi Tel was held classifiable under Heading 3003.31 and not under Heading 3304.00, in favour of the assessee.

Issue (ii): whether Castor (Erand) Oil was classifiable as an Ayurvedic medicament under Heading 3003.31 or under Heading 3003.20/3003.39 as adopted by the Revenue

Analysis: It was accepted that the product was a medicament, and the only dispute was whether it was Ayurvedic. The records showed that it was produced from Ayurvedic ingredients. Heading 3003.20 was held inapplicable because it covered medicaments other than those exclusively used in Ayurvedic medicine. The classification adopted below was therefore contrary to the terms of the heading.

Conclusion: Castor (Erand) Oil was held classifiable under Heading 3003.31, in favour of the assessee.

Issue (iii): whether Stimulex Capsules/Tablet was classifiable as an Ayurvedic medicament under Heading 3003.39 or as a food supplement under Heading 2108.99

Analysis: The ingredients were treated as recognised Ayurvedic ingredients and the product was found to be basically a medicinal preparation rather than a food supplement. The relevant HSN note distinguishing food supplements from preparations for prevention of disease supported this view, and the earlier classification of a similar product also supported the assessee's case. On that basis, the Revenue's classification as a food supplement was rejected.

Conclusion: Stimulex Capsules/Tablet was held classifiable under Heading 3003.39 and not under Heading 2108.99, in favour of the assessee.

Final Conclusion: All three disputed products were held to be Ayurvedic medicaments under the relevant tariff headings, and the Revenue's classifications were set aside.

Ratio Decidendi: Where a product is shown to be manufactured exclusively from Ayurvedic ingredients in accordance with authoritative Ayurvedic formulations and is medicinal in character, it is classifiable as an Ayurvedic medicament under the appropriate tariff entry rather than as a cosmetic or food supplement.

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