In Brief
The Supreme Court held that pure coconut oil packaged in small quantities (5 ml to 2 litres) should be classified as edible oil under Heading 1513 of the Central Excise Tariff Act, 1985, unless the packaging satisfies specific requirements to qualify as hair oil under Heading 3305. The Court reaffirmed that the Central Excise Tariff is based on the Harmonized System of Nomenclature (HSN), and when tariff entries align between the two systems, the HSN's Explanatory Notes provide binding guidance. Small packaging size alone does not indicate hair oil classification; the product must bear clear labels, literature, or indications showing cosmetic use. The Court dismissed the Revenue's appeals, holding that the burden lies on the Revenue to prove reclassification under clear evidence, not mere speculation about product use.
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