TaxTMI 
TaxTMI 
2026 (8) TMI 1318
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....f S1. No. 226 of Schedule-I of the Notification No.9/2025- Integrated Tax (Rate) dated 17.09.2025 under the Customs Tariff Act, 1975. 2. Applicant's Submissions: 2.1 The applicant, namely, M/s Huvepharma Sea (Pune) Pvt. Ltd., is a private limited company duly incorporated under the laws of India. The applicant has its registered office at 42, Haridwar Bungalow, S. No. 213, Road No. 2A/B, Kalyani Nagar, Pune, Maharashtra - 411006. For the purpose of import, the applicant operates a warehouse at Ground Floor, Mil No. 1969, Godown No.1, Wadki - Saswad Road, Taluka Haveli, Pune, Maharashtra - 412308. The applicant is a subsidiary of Huvepharma, a multinational company headquartered in Sofia, Bulgaria. 2.2 The applicant commenced its operations in India in May, 2010 and is, inter alia, engaged in the manufacture and supply of high-grade animal health and nutrition products, including antibiotics, classifiable under various headings of the Customs Tariff Act, 1975. 2.3 The present application has been filed by the applicant seeking an advance ruling on the applicable rate of Integrated Goods and Services Tax (IGST) on the import of specialised veterinary-grade compounds. ....
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....pidol is a pyridinol derivative, used as a potent coccidiostat in veterinary medicine. Its IUPAC name is 3, 5-dichloro-2, 6-dimethyl-1HI-pyridin-4-one. The PIQ is specifically approved as a therapeutic aid for the prevention of Coccidiosis in broiler chickens. Coccidiosis is a disease caused by parasite of Eimeria genus. Clopidol impacts by inhibiting the development of the parasite at the early sporozoite and trophozoite stages of its life cycle. By arresting the growth of parasite at these initial phases, Clopidol prevents the destruction of the animal's intestinal lining, thereby fulfilling a clear medicinal and prophylactic (preventative) function. The chemical structure of the PIQ is as follows: b) Clopidol is a recognized drug by the Central Drug Standards Control Organization ("CDSCO") and is imported as a 100% pure API. The relevant extract from the website is marked as below for reference: c) The medicinal nature of the product is further substantiated by a Veterinary Certificate dated 21.11.2025 issued by the Bulgarian Food Safety Agency. certifying that the product is fit for its intended veterinary medicinal use. Further, reliance is placed in subm....
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....dicinal formulations, and it is a 100% pure API. Amprolium is used both for the prevention and clinical treatment of intestinal Coccidiosis in poultry. The nature of the product as "drug" is further validated by a Veterinary Certificate issued by the Bulgarian Food Safety Agency dated 30.10.2024, confirming that the product is fit for its intended medicinal purpose for animals. h) The high-purity nature of the product as a therapeutic substance is established by the Certificate of a Pharmaceutical Product bearing no. BG48/2025 issued by the Bulgarian Food Safety Agency. The certificate confirms the composition as 100% Amprolium, and certifying it as a pharmaceutical-grade product. i) Further, reference is made to the Certificate of Free Sale issued by the Bulgarian Food Safety Agency, which certifies that Amprolium is an API. The certificate confirms that the product is a veterinary drug manufactured as per the required standards and is authorized for free sale on the territory of the exporting country for medicinal purposes. j) It is submitted that the Applicant imports Amprolium in accordance with the procedure laid down by the statute by duly obtaining....
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.... 29 of the CTA which covers Organic Chemicals and is discharging IGST liability at the rate of 18% as required under the relevant notification. F. The Applicant submits that the products are imported under valid Drug Licenses as stated above and are subjected to mandatory Assistant Drug Controller ("ADC") clearance at the time of import and therefore, the Applicant is entitled to apply IGST at the rate of 5% in terms of SI. No. 226 of the Schedule I of the IGST Notification. 4. In light of the foregoing facts, grounds and legal submissions, the Applicant has sought a ruling from this Authority on the following: whether the veterinary grade APIs imported by the Applicant, namely Clopidol (VET) and Amprolium 100% (VET), are eligible for the applicable IGST rate of 5% as per SI. No. 226 of Schedule I of Notification No. 09/2025-Integrated Tax (Rate) or otherwise. 5. APPLICANT'S ELIGIBILITY AND ADMISSIBILITY OF ADVANCE RULING: 5.1 In order to file an application before the Authority for Advance Ruling ("AAR"), the Applicant must satisfy the conditions prescribed under the Customs Act, 1962 ("Customs Act"). 5.2 Provisions related to Advance Rulings are ....
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....dent from the above, in the present case, the Applicant satisfies all the following conditions mandated for filing of the present application for advance ruling namely: 5.5.1 The Applicant is a company registered in India and is holding a valid Importer-Exporter Code ("IEC") Number 3109020467/4. Thus, the Applicant is rightly covered under the definition of 'Applicant' as provided under Section 28F(c)(i) for preferring this application. 5.5.2 Question raised in the application for advance ruling by the Applicant squarely falls within the ambit of Section 28H(2)(d) of the Customs Act. The Applicant wishes to obtain the advance ruling on questions relating to the applicability of Notification No. 09/2025- Integrated Tax (Rate) to the subject goods, i.e., Clopidol (VET) and Amprolium 100% (VET), and the determination of the applicable rate of IGST thereunder. Therefore, the question raised by the Applicant is regarding the applicability of IGST at the rate of 5% on the goods in questions fall squarely within the purview of the provisions of Section 28H(2)(d) of the Customs Act. 5.5.3 Further, the question(s) raised in the present case, have not been decided by the App....
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.... The submissions of the Applicant in this regard are as below: Condition (a): Nature of the goods imported should be either "Drugs or Medicines" (including salts, esters, and bulk drugs) 6.5 It is submitted that SI. No. 226 of the Notification specifies IGST @ 5% to all the drugs and medicines including their salts and esters and include formulations manufactured from bulk drugs, irrespective of the fact whether the drugs, medicines or formulations are in bulk or not. Statutory framework governing "drugs" and "medicine" under the laws of India 6.6 It is a well settled principle of interpretation that where a term used in a tax notification has a technical or legal meaning in the industry, it should be interpreted in the light of the statutes dealing with that specific subject matter. Therefore, to determine the scope of "All Drugs and Medicines" under SI. No. 226 of the Notification, one must look at the definitions given under the Drugs and Cosmetics Act, 1940. 6.7 Section 3 of the Drugs and Cosmetics Act, 1940 provides the definition of 'drugs'. The relevant portion is extracted below: ...(b) "drug" includes -- (i) all medicines for ....
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....les, 1945. 23. Import Licence - An import licence in Form 10 shall be required for import of drugs, excluding those specified in Schedule X. 27. Grant of import licence. - On receipt of an application for an import licence in the Form and manner prescribed in rule 24, the licensing authority shall, on being satisfied that, if granted, the conditions of the licence will be observed, issue an import licence in Form 10 or Form 10A, as the case may be. Form 41 as per Rule 27-A of The Drugs Rules, 1945. 27-A. Grant of Registration Certificates.:- (1) On receipt for an application for Registration Certificate in the Form and manner specified in Rule 24A, the licensing authority shall, on being satisfied, that, if granted, the conditions of the Registration Certificate will be observed, issue a Registration Certificate in Form 41. 6.12 Thus, as per the Drugs and Cosmetics Act and Rules made thereunder, an importer is required to obtain the aforementioned Form 10 and Form 41 to import any substance as a 'drug'. 6.13 Further, Rule 43 of the Drugs Rules, 1945, recognizes the situation when any substance that fall within the definition of "drugs" but the same is inte....
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.... as the Drug Controller, to be obtained online through a seamlessly integrated IT system. thereby simplifying and expediting the clearance process. 3. Circular No. 28/2016- Cus., dated 14-6-2016 This Circular focuses on the simplification of procedures in SWIFT specifically for consignments related to drugs and cosmetics. It introduces "necessary qualifiers" in the Integrated Declaration to replace the need for certain physical documents. Furthermore, it ensures that all ICES locations are mapped to the nearest Assistant Drug Controller (ADC) office for automated routing of consignments for regulatory clearance. Judicial precedents have consistently applied the provisions of Drugs and Cosmetics Act. 1940 in interpreting the tax entries. 6.18 In this regard, reliance is placed on the following judgements: a) Kumar Prabhulal Shah v. Union of India [1987 (1) TMI 81 - Bombay High Court]: The Hon'ble High Court, while examining the eligibility of substances for the purpose of determining the applicability of tax exemption, held that the definition of "drug" in Section 3(b) of the Drugs and Cosmetics Act is inclusive in nature and must be interpreted in its....
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....iagnosis, treatment, or prevention of a disease or as a component of a medication. * Medicine: An agent, such as a drug, used to treat disease or injury. Dictionary of Medical Terms (fourth edition) * Drug: a natural or synthetic chemical substance which is used in medicine and affects the way in which organs or tissues function * Medicine: a preparation taken to treat a disease or condition, especially one in liquid form f) From the above, it is evident that "drugs" generally include all substances intended for the diagnosis, treatment, mitigation, or prevention of disease in humans or animals, as well as substances intended for use as components of a drug. Therefore, it is submitted that APIs, fall squarely under the ambit of "drugs." The products in question squarely fall under the definition of "drugs" as per the Drugs and Cosmetics Act, 1940. g) From the analysis of the statutory framework, and judicial precedents, established above, it is evident that for an imported product to be legally classified as a "Drug," it must possess the following characteristics: a. It must be intended for the diagnosis, treatment, mitigation, or pre....
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....d by the CDSCO. They are imported under mandatory Form 10 and Form 41 in terms of Rule 23 and 27-A of the Drugs Rules. 1945. These license said licensesa are issued, exclusively for "Drugs" with medicinal properties. i) Therefore, the products in question, namely Amprolium and Clopidol, fall squarely within the primary functional definition of a "Drug" under Section 3(b)(i) of the Drugs and Cosmetics Act, 1940. j) The medicinal identity of these products is further evidenced by their inclusion in the "List of Veterinary Drugs Approved by CDSCO". It is pertinent to note that the very specific grades of the PIQs imported by the Applicant are recognized by the drug regulator as follows: SI. No. Drug Name Date of issue 6. Amprolium HCL Vet GRADE IP 30.08.2011 11. Clopidol (CP Vet) 26.06.2012 k) Therefore, the presence of the PIQs in this statutory list, along with the Import Licenses procured by the Applicant, serves as conclusive proof that the State recognizes these substances as "Drugs." The PIQs do not fall under the "PGA Exemption Category (PEC)" for Chemicals I) The Applicant submits that CBIC Circular No. 28....
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....Notification. The products are pharmacologically active, statutorily licensed as drugs, and recognized in the Notification. Consequently, it is submitted that the PIQs are in the form of "Drugs or Medicines" thereby fulfilling the abovesaid Condition (a) and are thus eligible for the 5% IGST rate. Condition (b): Classification under Chapter 30 or any other Chapter o) It is submitted that the SI. No. 226 of Schedule I of the Notification uses the phrase "30 or any other Chapter", thus making the entry based on nature of the goods imported rather than classification thereof. p) The presence of the phrase 'any other Chapter' in Column (2) of SI. No. 226 of Schedule I of the notification implies that for the purpose of the 5% rate, the nature of the product being a drug or a medicine overrides the HSN classification. q) Hence, 5% IGST is applicable to all goods satisfying the nature of "Drugs and Medicines," regardless of their technical classification in the Tariff. The products in question classified under Chapter 29 are rightly covered under SI. No. 226 of Schedule I and not under SI. No. 36 of Schedule II of the Notification. ....
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....tion in SI. No. 36 of the Notification. In case of an overlap between the two entries, the legal right to choose the more beneficial rate resides with the Applicant. w) It is submitted that when a product is arguably covered under two different entries of a Taxing Notification, the choice of the more beneficial rate resides exclusively with the taxpayer. The interpretation of taxing notification entries must be conducted in a manner that is reasonable, fair, and consistent with the legislative intent to provide relief. x) It is a well-settled principle that the interpretation of a taxing notification entry should be described in the way as mentioned in the law only. The Department cannot deprive a bona fide taxpayer of a benefit available in law with a view to augment the quantum of duty. Therefore, if the PIQs satisfy the criteria for a "Drug" (5% rate), the Revenue cannot forcibly classify them as "Chemicals" (18% rate) simply because the latter results in higher tax collection. y) In this regard, reliance is placed on the ration in Share Medical Care v. Union of India [2007 (2) TMI 2 - SC], wherein the Hon'ble Supreme Court has held the fo....
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.... a particular notification at the initial stage, he is not debarred, prohibited or estopped from claiming such benefit at a later stage. ....... 20. In our opinion, the decision in Mediwell Hospital would not take away the right of the appellant to claim benefit under para 3 of the Table of exemption notification. If the appellant is not entitled to exemption under para 2, it cannot make grievance against denial of exemption. But if it is otherwise entitled to such benefit under para 3, it cannot be denied either. The contention of the authorities, therefore, has no force and must be rejected ... (emphasis supplied) z.) Since the products in question satisfy the description of 'Drugs' under SI. No. 226 of Schedule I, the Applicant is entitled to the greater and larger relief at the 5% rate. Any ambiguity in a taxing notification must be resolved in favour of the taxpayer aa) It further submitted that the IGST Rate Notification is a "Taxing Notification" and not an "Exemption Notification." Consequently, any ambiguity regarding which entry is applicable must be resolved in favour of the taxpayer. bb) Reliance is also p....
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....ducts satisfy Condition (b) while remaining squarely within the ambit of Chapter 29. Condition (e): The products in question should not be covered under the NIL rate specified at SI. No. 113 of Notification No. 10/2025-Integrated Tax (Rate). ff) Notification No. 10/2025- Integrated Tax (Rate) dated 17.09.2025 is an exemption notification granting relief to supplies of goods of such description as specified therein. SI. No. 113 of the above said notification is extracted below: SI. No. Chapter/Heading/Sub-heading / Tariff item Description of Goods . 113 30 or any other Chapter Drugs and medicines listed in Annexure 1. Annexure-I appended to the Schedule to the said Notification specifies the following item at Sr. No. 113, as reproduced in the table below: Annexure-I [See Sr.No. 113 of the Schedule] Sr. No. List of drugs or medicines 1. Gene Therapy 2. Agalsidase Beta 3. Imiglucerase 4. Eptacog alfa activated recombinant coagulation factor VIIa 5. Onasemnogene abeparvovec 6. Asciminib 7. Mepolizumab 8. Pegylated Liposomal Irinotecan 9. Daratumumab 10. Daratumumab subcutaneous ....
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....regulatory licensing under the Drugs and Cosmetics Act, 1940. Once a product is recognized and licensed as a "drug" by the CDSCO, it cannot be stripped of that identity merely because it is imported in bulk or intended for a specific stage of use, such as bioequivalence testing or clinical research. b. On a reading of Section 3(b) of the Drugs and Cosmetics Act, 1940, together with the Drugs (Price Control) Order and the New Drugs and Clinical Trials Rules, 2019, this Authority concluded that APIs/bulk drugs naturally fall within the statutory meaning of "drug". c. It was held that SI. No. 226 (covering "All drugs and medicines") is a specific, description-based entry that prevails over general chapter-based entries for organic or inorganic chemicals (SI. No. 35 or 36 of Schedule II). C.4 It is submitted that the PIQs in the case of the Applicant are APIs, regulated by the CDSCO and imported as per the relevant norms laid down by the Drugs Act and Rules. C.5 It is submitted that the facts in the present case are even better to justify the claim of the Applicant in as much as the goods so imported are not be used for R&D purposes rather the same are used for ....
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....nce Rulings, Andhra Pradesh, examined the classification of products that, while manufactured as bulk drugs, were explicitly listed in List 1 of SI. No. 180. The Authority held that these products were squarely covered by the concessional entry, and affirmed that a specific entry overrides a general entry, thereby making the commodities eligible for the lower 5% rate. b. In Re: M/s Biocon Ltd. [Order No. KAR/AAAR-06/2020-21]: The Karnataka Appellate Authority for Advance Ruling determined that the drug in question, which required reconstitution before administration, qualified as a drug "for injection" and ruled that the phrase "for injection" in the notification refers to the form of the drug rather than acting as a restriction on its status as a drug, thus allowing the benefit of the concessional rate. E.2 From the abovementioned precedents it is seen that "Drugs" and "APIs" retain their identity and are eligible to discharge IGST @ 5% as long as they are covered in the exempting notifications, regardless of their stage of manufacture or commercial nomenclature. By following the principle of generalia specialibus non derogant, authorities have ensured that the s....
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....enefit of IGST at the rate of 5% as per SI. No. 226 of Schedule I of Notification No. 09/2025-Integrated Tax (Rate)? Applicant's Understanding: Yes, the veterinary grade APIs imported by the Applicant, namely Clopidol (VET) and Amprolium 100% (VET), are eligible to pay IGST at the rate of 5% as per SI. No. 226 of Schedule I of Notification No. 09/2025-Integrated Tax (Rate). 11. Port of Import and reply from jurisdictional Commissionerate: The applicant in their CAAR-I indicated that they intend to import the subject goods at the jurisdiction of Office of the 1) The Pr. Commissioner of Customs, Nhava Sheva-1, Jawaharlal Nehru Customs House (JNCH). Nhava Sheva 2) The Commissioner of Customs (Import), Air Cargo Complex (ACC), Sahar, Andheri East. Mumbai. The application was forwarded to the concerned Commissionerate's for their comments on 03.07.2026 and 20.07.2026 respectively, however, no comments/reply were received from the jurisdictional authority. 12. Details of Personal Hearing: A personal hearing in the matter was held on 16.07.2026. The authorised representative of the applicant appeared and reiterated the submissions made in the application as well as t....
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....ts medicinal nature is established by the following documents issued by the Bulgarian Food Safety Agency: (i) Veterinary Certificate dated 30.10.2024, certifying its suitability for veterinary medicinal use: (ii) Certificate of a Pharmaceutical Product No. BG48/2025, confirming that the product is 100% Amprolium of pharmaceutical grade; and (iii) Certificate of Free Sale, certifying the product as a veterinary API authorized for medicinal use. 13.4 The product packaging prominently bears the labels "Veterinary Drug". "For Animal Treatment Only" and "Not for Human Use", confirming its exclusive veterinary medicinal use. This version removes repetition, groups similar evidence together and presents the facts in a more precise and legally concise manner while preserving all substantive points. 13.5 At the outset, I find that the issue raised in the question in the form CAAR -! is squarely covered under Section 2811(2) of the Customs Act, 1962, being a matter related applicability of duty (IGST rate in the present case) under the provisions of this Act. The question posed for advance ruling is: "Whether Integrated Goods and Services Tax (IGST) ....
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....plam 52. Obinutuzumab 53. Polatuzumab vedotin 54. Entrectinib 55. Atezolizumab 56. Spesolimab 57. Velaglucerase Alpha 58. Agalsidase Alfa 59. Rurioctocog Alpha Pegol 60. Idursulphatase 61. Alglucosidase Alfa 62. Laronidase 63. Olipudase Alfa 64. Tepotinib 65. Avelumab 66. Emicizumab 67. Belumosudil 68. Miglustat 69. Velmanease Alfa 70. Alirocumab 71. Evolocumab 72. Cystamine Bitartrate 73. CI-Inhibitor injection 74. Inclisiran In view of the above table and upon perusal of Annexure -! to the said Notification. it is evident that the subject goods proposed to be imported by the Applicant, namely 1) Clopidol (VET) and 2) Amprolium 100% (VET), both being veterinary-grade APIs, are not covered under Annexure I to the said Notification. 13.8 As discussed above, SI. No. 226 of Schedule I (5%) covers all drugs and medicines. The applicant has contended that the bulk Drugs/APIs" are covered under the expression "All Drugs and Medicines" and are covered under SI. No. 226 being drugs. Therefore, it is to be analysed: "Whether "Bulk Drugs/API....
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....maceutical, chemical, biological or plant product including its salts, esters, isomers, analogues and derivatives, conforming to standards specified in the Drugs and Cosmetics Act, 1940 (23 of 1940) and which is used as such or as an ingredient in any formulation; "(i) "formulation" means a medicine processed out of or containing one or more drugs with or without use of any pharmaceutical aids, for internal or external use for or in the diagnosis, treatment, mitigation or prevention of disease and, but shall not include (i) any medicine included in any bonafide Ayurvedic (including Sidha) or Unani (Tibb) systems of medicines; (ii) any medicine included in the Homeopathic system of medicine; and (iii) any substance to which the provisions of the Drugs and Cosmetics Act, 1940 (23 of 1940) do not apply;" In view of above bulk drug refers to pharmaceutical or chemical substances used as such or as an ingredient in any formulation. Accordingly, I observe that on conjoint reading of the above definition of API with Section 3(b) of the Drugs and Cosmetics Act, bulk drugs/APIs bulk drugs falls within the statutory meaning of "drug". 13.6 Judicial P....
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.... canon of statutory interpretation that an entry must be construed in a manner that gives meaning and effect to every word used therein, and avoids any interpretation that would render a part of the provision otiose. 13.7.3 Moreover, the entry applies to goods falling under "Chapter 30 or any Chapter." The deliberate use of the expression "or any Chapter" manifests a clear legislative intent to extend the scope of coverage beyond Chapter 30, thereby encompassing drugs and drug substances classifiable under other Chapters, including Active Pharmaceutical Ingredients (APIs) falling under Chapters 28 and 29. 13.7.4 Reliance is placed on Commissioner of Customs (Import), Mumbai v. Dilip Kumar & Company, 2018 (361) E.L.T. 577 (S.C.), wherein the Supreme Court held that any ambiguity in a taxing provision must be construed in favour of the taxpayer, while the rule of strict interpretation applies only to exemption notifications. Since Notification No. 09/2025-Integrated Tax (Rate) is a taxing notification, any ambiguity therein must be interpreted in favour of the Applicant. 13.7.5 It is submitted by the applicant that there is plethora of decisions that hold that the term "drug....
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....d nutrient absorption, high mortality rates, and secondary bacterial infections in poultry. The compounds proposed to be imported by the applicant are indispensable Active Pharmaceutical Ingredients (APIs) used exclusively in the veterinary sector for the prevention and treatment of this disease and Central Drugs Standards Control Organisation (CDSCO), the authority which approves drugs in India, has granted approval for the drug " 13.8 Further, I observed that the impugned products are classified by the applicant under Chapter sub-heading 2941 90 90. The terms "Bulk drug" and "drug" have not been defined either in the rate notification or in the GST laws. However, the same have been defined in the Drugs (Prince Control) Order, 1995, as amended 2013, which is reproduced below: 2. Definitions : In this Order, unless the context otherwise requires, - (a) "active pharmaceutical ingredients or bulk drug" means any pharmaceutical, chemical, biological or plant product including its salts, esters, isomers, analogues and derivatives, conforming to standards specified in the Drugs and Cosmetics Act, 1940 (23 of 1940), and which is used as such or as an ingredient in an....
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....ontrol Organisation (CDSCO), the authority which approves drugs in India has granted approval for the drug Clopidol which indicate as Coccidiosis which is used for bacterial infections in poultry. The certificate confirms that the substance comprises 100% pure Clopidol and is intended for medicinal use. The medicinal status of the product is further corroborated by the Certificate of Free Sale issued by the Bulgarian Food Safety Agency. This certificate explicitly identifies the product as an API and confirms that it is a veterinary drug for medicinal use. 13.9 It appears that the API may come under the definition of bulk drugs if it is used for purpose of the diagnosis, treatment, mitigation or prevention of any disease or disorder in human beings or animals as per the section 3(b) of the Drugs and Cosmetic Act, 1940 and the drugs appears to be attracting IGST rate as per Sr. No. 226 of schedule I of Notification No. 09/2025-Integrated Tax (Rate) dated 17th September, 2025. In the instant case, the applicant proposed to be imported active pharmaceutical ingredient (API) for the intended for exclusive use in the veterinary sector to prevent and treat parasitic infections in poul....
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.... strictly and the burden to prove applicability would rest upon the tax payer and that the benefit of any ambiguity in the Notification must be interpreted in favour of the Revenue. The Principal Commissioner committed an error in assuming that the IGST Rate Notification is an Exemption Notification. The IGST Rate Notification is at rate Notification and, therefore, a Taxing Notification. It has to be strictly construed and any ambiguity has to be interpreted in favour of the tax payer and against the Revenue as was observed by the Supreme Court in Safari Retreats .... (emphasis supplied) Since the subject products satisfy the statutory and functional requirements of "drugs," they are appropriately covered under the specific entry at SI. No. 226 of Schedule I. Hence, the general classification under Chapter 29 cannot prevail over the specific entry applicable to medicinal products. 13.11 In contrast, SI. No. 226 specifically covers "All drugs and medicines ... ". without being confined to any particular Chapter of the Tariff. The scope of this entry is description-based rather than Chapter-based, and therefore it operates as a specific entry covering goods answering to the....
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....oultry. 14.2 Under Section 3(b) of the Drugs and Cosmetics Act, 1940, the definition of "drug" expressly includes medicines intended for use in animals for diagnosis, treatment, or prevention of diseases. Accordingly, these APIs are recognized as veterinary drugs and are subject to statutory regulatory requirements, including import licensing under the Drugs and Cosmetics Rules, 1945. Their pharmaceutical character is further supported by CDSCO recognition, pharmacopocial standards, and relevant veterinary certifications. 14.3 SI. No. 226 of Schedule I to Notification No. 09/2025-Integrated Tax (Rate) provides a IGST rate for "all drugs and medicines" and expressly covers goods falling under "Chapter 30 or any Chapter." The entry is description based and does not restrict its application only to finished formulations. Therefore, APIs having established medicinal use and regulatory recognition are covered within the scope of the entry, irrespective of their tariff classification under Chapters 28 or 29. The principle that a specific description prevails over a general classification supports the view that goods satisfying the functional description of "drugs and medicines" can....