Specific tariff entry prevails for book binding cloth; coated textile fabrics fall under the precise heading, not the general textile entry.

Dyed book binding cloth was held classifiable under Heading 5901.10 rather than Heading 52.06 because the tariff must be read by specific description and use, not by a single isolated physical feature. The goods were described and used as book binding cloth, and the test report showed heavy coating with gum and amylaceous substances, bringing them within the heading for textile fabrics coated for outer book covers. The remand order did not restrict the fresh classification exercise to permanent stiffness or imperviousness to water; the issue remained open on retested samples and other material. The lower classification was set aside and the Revenue's appeal succeeded.

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Issues: Whether dyed D/C book binding cloth was correctly classifiable under Heading 52.06 or under Heading 5901.10 of the Central Excise Tariff Act, and whether the remand order confined the classification exercise to the questions of permanent stiffness and imperviousness to water.

Analysis: The remand order did not direct classification on the sole basis of stiffness or imperviousness to water; it left the classification issue open to be decided afresh on the retested samples and other material. In tariff interpretation, the specific description governs over a general description. The goods were described and used as book binding cloth, and the test report showed that the fabric was heavily coated with gum and amylaceous substances. Heading 5901.10 specifically covers textile fabrics coated with gum or amylaceous substances of a kind used for the outer covers of books or the like, while the stiffness criterion was relevant to other fabrics such as buckram and similar stiffened textile fabrics. The decisions relied upon by the assessee and the lower authorities were distinguishable on facts, whereas the precedents cited by the Revenue directly concerned book binding cloth.

Conclusion: The impugned goods were classifiable under Heading 5901.10 and not under Heading 52.06; the Revenue's contention succeeded.

Final Conclusion: The classification adopted by the lower authorities was set aside and the Revenue's appeal was allowed.

Ratio Decidendi: In tariff classification, a specific entry covering the exact description and use of the goods prevails over a general textile heading, and classification must be made on the statutory heading as a whole rather than on a single isolated physical characteristic.

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