Specific tariff entry prevails over residual electronic-goods entry for electronic cash registers; essential character controls classification.

Electronic cash registers were treated as cash registering machines under the specific tariff entry rather than being moved to the residual electronic-systems entry. The language of Entry 90, which covered cash registering machines without limiting their mode of operation, prevailed over the broader and residual wording of Entry 97(b). Applying the rule that a specific entry overrides a general one, the Court found that additional electronic functions did not change the goods' essential character as cash registers. The assessee's attempt to claim the lower rate under the residual entry therefore failed, and classification remained under Entry 90.

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Issues: Whether electronic cash registers were classifiable under Entry 90 of Schedule C, Part II of the Bombay Sales Tax Act, 1959, or under Entry 97(b) of the same Schedule.

Analysis: The competing entries had to be construed on their language. Entry 90 specifically covered cash registering machines and other enumerated machines without any express limitation as to the mode of operation, while Entry 97(b) was framed as a residual category for electronic systems, instruments, apparatus and appliances other than those specified elsewhere. The principle that a specific entry prevails over a general entry was applied. The Court held that where the description in the specific entry fully covered the goods, resort to the broader electronic-goods entry was impermissible. The fact that the machines performed additional electronic functions did not alter their essential character as cash registering machines. The Court also noted that the assessee had originally collected tax at the rate applicable to Entry 90 and had claimed the lower rate under Entry 97(b) only after a rate-reducing notification.

Conclusion: Electronic cash registers were classifiable under Entry 90 and not under Entry 97(b); the assessee's claim to the contrary failed.

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