Perfumed hair oil classification turns on added perfume, with specific tariff entry prevailing over competing treatment.

A hair product that admittedly contained added perfume and fragrance added at the end of manufacture was held to fall within the specific tariff entry for perfumed hair oil under Heading 3305.10. The Court accepted the Tribunal's view that disclosure of the ingredients and manufacturing process supported that classification, and it found no need to decide any possible therapeutic character once the tariff description was satisfied. The Revenue's contrary classification challenge therefore failed, and the product remained assessable as perfumed hair oil.

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Issues: Whether the product manufactured by the respondent was classifiable as perfumed hair oil under Heading 3305.10 of the Central Excise Tariff Act, 1985, and not under the competing entries claimed by the Revenue or as an Ayurvedic medicament.

Analysis: The product was found to contain fragrance added at the end of the manufacturing process, and perfume formed one of its ingredients. The Court noted that the respondent had disclosed both the ingredients and the manufacturing process. On that basis, and without entering into the question whether the product had therapeutic value, the Court agreed with the Tribunal that the goods answered the description of perfumed hair oil. The Court therefore accepted the classification under Heading 3305.10 and found no merit in the Revenue's challenge. The classification principles applied were that where perfume is admittedly added, the product falls within the specific tariff entry for perfumed hair oil rather than a contrary or residuary treatment.

Conclusion: The product was correctly classified as perfumed hair oil under Heading 3305.10, and the Revenue's appeal failed.

Ratio Decidendi: Where a product for use on hair admittedly contains added perfume, it is classifiable under the specific tariff entry for perfumed hair oil, and the Court need not decide its possible medicinal character if the classification issue is otherwise resolved.

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