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Issues: (i) Whether the imported powdered extract derived from the root of Pelargonium sidoides, with maltodextrin as carrier, is classifiable under Heading 1302 or under Heading 3003 of the First Schedule to the Customs Tariff Act, 1975; (ii) whether the goods are eligible for concessional duty under Notification No. 45/2025-Cus. dated 24.10.2025.
Issue (i): Whether the imported powdered extract derived from the root of Pelargonium sidoides, with maltodextrin as carrier, is classifiable under Heading 1302 or under Heading 3003 of the First Schedule to the Customs Tariff Act, 1975.
Analysis: Heading 1302 covers vegetable saps and extracts, but the Explanatory Notes exclude products that, by reason of further processing, addition of other substances, or therapeutic/prophylactic character, acquire the character of medicaments or fall within more specific pharmaceutical headings. The product here was found to be a standardized hydro-ethanolic extract, vacuum dried, mixed with maltodextrin, and imported exclusively for pharmaceutical manufacture and therapeutic use. On that basis, it was treated as more than a crude botanical extract and as a mixed preparation having the essential character of a medicament.
Conclusion: The goods are classifiable under Heading 3003, specifically under sub-heading 3003 90 90, and not under Heading 1302.
Issue (ii): Whether the goods are eligible for concessional duty under Notification No. 45/2025-Cus. dated 24.10.2025.
Analysis: The claimed concession was linked to goods falling under Heading 1302. Once the goods were determined to be classifiable under Heading 3003, the notification-based concessional treatment claimed by the applicant could not apply to them.
Conclusion: The goods are not eligible for the benefit of concessional duty under Notification No. 45/2025-Cus. dated 24.10.2025.
Final Conclusion: The ruling settles the tariff classification against the applicant's claimed vegetable-extract heading and confirms classification as a pharmaceutical preparation, with the consequential denial of the claimed customs-duty concession.
Ratio Decidendi: A standardized plant extract, after processing and addition of an inert carrier, is classifiable as a medicament under Heading 3003 when its essential character is therapeutic and it is imported as a pharmaceutical intermediate rather than as a crude vegetable extract.