Specific tariff heading prevails over residual heading for chair parts, with classification upheld under Heading 9401.

Plastic chair bases and chair tops were classified by reference to the Central Excise Tariff Act, 1985 read with the HSN notes. The HSN notes for Heading 9401 specifically covered parts of chairs, including seats and related components, while Heading 9403 applied only to general-use furniture and excluded goods already covered elsewhere in the tariff. Because chair parts were specifically described under Heading 9401, the broader residual Heading 9403 could not govern the disputed goods. The classification under Heading 9403 was rejected and classification under Heading 9401 was upheld.

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Issues: Whether plastic chair base and chair top were classifiable under Heading 9403 or under Heading 9401 of the Central Excise Tariff Act, 1985.

Analysis: The classification was determined by reference to the Central Excise Tariff Act, 1985 read with the Harmonized System of Nomenclature. The relevant HSN notes for Heading 9401 covered parts of chairs, including seats and other components, while Heading 9403 was confined to furniture for general use and excluded furniture and parts covered by earlier headings. Since chairs and their parts were specifically covered under Heading 9401, the broader heading 9403 could not govern the disputed goods.

Conclusion: The goods were held classifiable under Heading 9401 and not under Heading 9403, in favour of Revenue.

Final Conclusion: The impugned classification under Heading 9403 was rejected and the Revenue's position on classification under Heading 9401 was upheld.

Ratio Decidendi: Where the tariff and HSN notes specifically cover chair parts under a particular heading, classification must follow that specific heading and a broader residual heading cannot be applied.

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