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Issues: Whether Hajmola Candy is classifiable under sub-heading 3003.30 as an Ayurvedic medicament or under sub-heading 1704.90 as sugar confectionery.
Analysis: The product was examined in the light of its ingredients, its similarity to the product considered by the Madhya Pradesh High Court in Panama Chemical Works, and the absence of any contrary High Court or Supreme Court authority. The relevant consideration was whether the product, though containing substantial sugar, retained the character of an Ayurvedic medicament having ingredients found in authoritative Ayurvedic texts, rather than being treated as confectionery merely because of its taste or sugar content.
Conclusion: Hajmola Candy is classifiable under sub-heading 3003.30 as an Ayurvedic medicament, and not under sub-heading 1704.90 as sugar confectionery.
Final Conclusion: The impugned classification was set aside and the assessee succeeded in obtaining the claimed excise classification relief.
Ratio Decidendi: Where the ingredients and character of a product correspond to an Ayurvedic formulation recognised in authoritative texts, substantial sugar content and confectionery-like form do not by themselves alter its classification as a medicament.