Fixed dose vitamin-and-iron medicament classified under Chapter 30, not as a vitamin mixture under Chapter 29

A fixed dose combination of vitamins and iron in Sipro Syrup was treated as a medicament for tariff purposes, so the classification fell under Chapter 30 rather than Chapter 29. The Tribunal relied on an earlier Larger Bench view, followed in subsequent Tribunal reasoning, that such fixed dose combinations are classifiable as patent and proprietary medicaments under sub-heading 3003.10. On that basis, the classification under sub-heading 2936.00 as a mixture of vitamins was rejected, and the classification accepted by the Commissioner (Appeals) was left undisturbed.

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Issues: Whether the product 'Sipro Syrup', a formulation containing vitamins and iron, was classifiable as a patent and proprietary medicament under sub-heading 3003.10 or as a mixture of vitamins under sub-heading 2936.00.

Analysis: The product consisted of a fixed dose combination of vitamins and iron. The Tribunal noted that an identical classification dispute concerning a similar product had already been decided by the Larger Bench, which held that such fixed dose combinations fall under Chapter 30.03. That view had also been endorsed in an earlier Tribunal decision. Following the binding Larger Bench ratio, the Tribunal found no reason to disturb the classification accepted by the Commissioner (Appeals).

Conclusion: The product was correctly classified under sub-heading 3003.10 as a patent and proprietary medicament, and the Revenue's claim for classification under sub-heading 2936.00 was rejected.

Ratio Decidendi: A fixed dose combination of vitamins and iron, treated as a medicament, is classifiable under Chapter 30.03 rather than as a vitamin mixture under Chapter 29.36.

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